PB98-964501
EPA 541-R98-027
October 1998
EPA Superfund
Record of Decision:
Treasure Island Naval Station
Hunters Point Annex (Parcel B)
San Francisco, CA
10/9/1997
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Comprehensive Long-Term Environmental Action Navy (CLEAN I
Contract # N62474-94-D-7609
HUNTERS POINT SHIPYARD
PARCEL B
FINAL RECORD OF DECISION
October 7,1997
(Pursuant to the Comprehensive Environmental Response,
Compensation, and Liability Act)
Department of the Navy
Engineering Field Activity West
San Bruno, California 94066-2402
Department of the Navy Engineering Field Activity West
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HUNTERS POINT SHIPYARD
PARCEL B
FINAL RECORD OF DECISION
October 7,1997
(Pursuant to the Comprehensive Environmental Response,
Compensation, and Liability Act)
Issued by
U.S. DEPARTMENT OF THE NAVY
Engineering Field Activity West
Naval Facilities Engineering Command
San Bruno, California
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CONTENTS
Section Page
1.0 DECLARATION 1
1.1 SITE NAME AND LOCATION 1
1.2 STATEMENT OF BASIS AND PURPOSE 1
1.3 ASSESSMENT OF THE SITE 1
1.4 DESCRIPTION OF THE SELECTED REMEDY 2
1.5 STATUTORY DETERMINATIONS 4
2.0 DECISION SUMMARY : 6
2.1 SITE NAME, LOCATION, AND DESCRIPTION 6
2.2 SITE HISTORY 10
2.2.1 Installation Development 10
2.2.2 Environmental Investigations 10
2.2.3 Removal Actions 11
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 14
2.4 SCOPE AND ROLE OF THE RESPONSE ACTION 15
2.5 PARCEL B SITE CHARACTERISTICS 16
2.6 SUMMARY OF SITE RISKS 17
2.6.1 Human Health Risk Assessment 17
2.6.2 Ecological Risk Assessment 27
2.7 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS 28
2.8 DESCRIPTION OF ALTERNATIVES 33
2.8.1 Soil Alternatives 33
2.8.2 Groundwater Alternatives : 54
2.9 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 61
2.9.1 Soil Alternatives 61
2.9.2 Groundwater Alternatives 63
2.10 SELECTED REMEDY 65
2.11 STATUTORY DETERMINATIONS 72
2.12 DOCUMENTATION OF SIGNIFICANT CHANGES 72
REFERENCES 74
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CONTENTS (Continued)
Appendix
A SUMMARY OF HAZARDOUS SUBSTANCES EXCEEDING SCREENING CRITERIA
B RESPONSIVENESS SUMMARY
FIGURES
Figure Page
1 FACILITY LOCATION MAP 7
2 HUNTERS POINT SHIPYARD PARCEL LOCATION MAP 8
3 PARCEL B SITE MAP 13
4 GRID AREAS IN WHICH POTENTIAL CARCINOGENIC RISK EXCEEDS 10"* OR HI
EXCEEDS 1: FUTURE RESIDENTIAL SCENARIO 26
5 SOIL EXCAVATION AREAS 67
6 GROUNDWATER MONITORING PLAN SCHEMATIC 70
TABLES
Table Page
1 PARCEL B SITE DESCRIPTIONS 12
2 HUNTERS POINT SHIPYARD PARCEL B POTENTIAL RISKS UNDER CURRENT
INDUSTRIAL EXPOSURE SCENARIO 21
3 HUNTERS POINT SHIPYARD PARCEL B POTENTIAL RISKS UNDER FUTURE
INDUSTRIAL EXPOSURE SCENARIO 22
4 HUNTERS POINT SHIPYARD PARCEL B POTENTIAL RISKS UNDER FUTURE
RESIDENTIAL EXPOSURE SCENARIO 24
5 ARARS FOR SOIL ALTERNATIVES 34
6 ARARS FOR GROUNDWATER ALTERNATIVES 38
7 COMPONENTS OF SOIL ALTERNATIVES 42
8 SOIL CLEANUP STANDARDS 44
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CONTENTS (Continued)
TABLES
Table Page
9 OFF-SITE MANAGEMENT APPROACHES FOR CONTAMINATED SOILS 48
10 GROUNDWATER MONITORING TRIGGER LEVELS - PARCEL B 57
11 PROPOSED REMEDIAL DESIGN/REMEDIAL ACTION SCHEDULE 66
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1.0 DECLARATION
1.1 SITE NAME AND LOCATION
This record of decision (ROD) is for Hunters Point Shipyard (HPS), Parcel B, in San Francisco,
California. HPS was deactivated and placed on industrial reserve in 1974. In 1989, HPS was placed on
the National Priorities List (NPL). In 1991, HPS was selected and approved for closure under the Base
Realignment and Closure (BRAC) Program.
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Installation Restoration Program
(IRP) sites located on Parcel B at HPS in San Francisco, California. The remedy was chosen in
accordance with the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act, and the National
Contingency Plan (NCP).
The decision is based on the administrative record for Parcel B at HPS.
The U.S. Environmental Protection Agency (EPA) and the State of California concur on the selected
remedy.
1.3 ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from Parcel B, if not addressed by implementing
the response action selected in this ROD, may present a potential threat to public health, welfare, or the
environment.
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1.4 DESCRIPTION OF THE SELECTED REMEDY
This ROD addresses both soil and groundwater contamination for CERCLA hazardous substances at
HPS Parcel B. Remediation of areas in which CERCLA hazardous substances are commingled with
petroleum hydrocarbons is also addressed by this ROD. Areas containing only petroleum hydrocarbons,
which are not hazardous substances as defined by CERCLA, will be addressed in a separate corrective
action plan (CAP) under the oversight of the California Regional Water Quality Control Board
(RWQCB), San Francisco Bay Region. The Navy's goal is to coordinate cleanup of CERCLA and non-
CERCLA hazardous substances to facilitate property transfer under BRAC.
The Navy has selected excavation and off-site disposal as the final remedy for Parcel B soil. The major
components of the selected remedy for soil are as follows:
Excavation of contaminated soil to the groundwater table or 10"6 cancer risk (residential)
Off-site disposal of contaminated soil (the soil will be treated at the off-site landfill if
necessary to meet land disposal restrictions)
Placement of clean backfill in the excavated areas
Deed notification indicating that soil below the groundwater table in remediated areas, as
specified in the remedial action close-out report, may be contaminated. All future soils
excavated from below the groundwater table in remediated areas must be managed in
accordance with federal, State and local laws and requirements including local
ordinances such as Articles 4.1 and 20 of the San Francisco Public Works Code. In
addition, any owner and/or tenant of Parcel B who excavates soils containing levels of
contaminants in excess of the cleanup goals presented in Table 8 of this ROD will be
restricted from placing the excavated soils onto the ground surface and restricted from
mixing the excavated soils with soils present in the surface to groundwater zone.
The major components of the selected remedy for groundwater are as follows:
Lining of the storm drains and pressure grouting of the storm drain bedding material at
IRP sites IR-07 and IR-10 in those locations where the storm drain system is below the
groundwater table in an affected groundwater area
Removal of steam and fuel lines
Deed restrictions on Parcel B such as prohibiting all uses of groundwater within the
shallow water-bearing zone(s) to 90 feet below ground surface, and notification of the
lining of the storm drains are detailed in the selected remedy section of this ROD
Deed notification indicating that contamination may be present in the groundwater in the
remediated areas as specified in the remedial action close-out report. Surface discharge
of contaminated groundwater is prohibited.
Groundwater monitoring for up to 30 years to evaluate the effectiveness of the soil
source removal actions and to monitor concentrations of hazardous substances that may
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migrate toward San Francisco Bay. Groundwater monitoring at IR-10 to monitor the
future potential degradation of trichloroethene (TCE) to vinyl chloride.
The groundwater monitoring program will be developed during remedial design (RD). After 5 years of
monitoring, the entire groundwater monitoring program, including the analyses conducted, the frequency
of sampling, and the overall duration of the monitoring program, will be re-evaluated as part of the 5-year
review as required under CERCLA. Should the Navy wish to terminate the monitoring program, such
modification would have to be justified and would likely result in the amendment of this ROD. The
Navy shall monitor the groundwater to ensure that the national ambient water quality criteria (NAWQC)
as set forth in the Central Valley RWQCB's 1995 Compilation of Water Quality Goals or state water
quality objectives as set forth in the 1995 Water Quality Control Plan for the San Francisco Bay Region
(the Basin Plan) and the ambient concentration of metals, whichever is higher, are not exceeded at the
high tide line of the Parcel B tidally influenced zone, which is the point of compliance. A groundwater
monitoring plan that uses a 5-year buffer zone upgradient of the tidally influenced zone will be instituted.
A series of sentinel wells will be located upgradient from the point of compliance a distance equivalent
to a groundwater travel time of 5 years. The groundwater monitoring data from these sentinel wells will
be compared to 10 times NAWQC and the ambient concentrations of metals. If groundwater monitoring
indicates that concentrations of hazardous substances exceed these criteria, the Navy will undertake the
following actions:
Orally notify EPA, California EPA Department of Toxic Substances Control (Cal/EPA-
DTSC), and the RWQCB (the signatory agencies) within 15 days of any exceedance of
the groundwater monitoring criteria followed by a written notice to the signatory
agencies within 15 days of the oral notification
Consult with the signatory agencies regarding the exceedance
Conduct monitoring to verify the exceedance in accordance with the monitoring plan
(which will be developed during the remedial design/remedial action phase)
At the written request of one or more of the signatory agencies, develop a proposal for
their review and comment as to what should be done to address the exceedance, which
may result in a change in the remedy
The Navy recognizes that a change to the groundwater remedy may require a ROD amendment. Any
changes will be developed and presented to the public and implemented in accordance with the
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requirements of CERCLA. The FFA shall continue to apply through operation and maintenance (O&M)
of the Parcel B response action.
During the RD phase, the Navy will develop a groundwater model to calculate a site-specific multiplier
to be applied to the NAWQC/Basin Plan water quality objectives and ambient metal concentrations to
reflect the expected dilution attenuation that is likely to occur as contamination migrates from the
monitoring well to the Bay. Once these site-specific criteria are developed and approved by the signatory
agencies, the Navy will replace the 10 times default criteria as the trigger for taking the actions listed
above.
1.5 STATUTORY DETERMINATIONS
The selected remedy for soil and groundwater is protective of human health and the environment,
complies with federal and state requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes permanent solutions to the maximum extent
practicable for this site. However, it does not satisfy the statutory preference for remedies that employ
treatment to reduce toxicity, mobility, and volume as a principal element. This is due to numerous
comments received during the public comment period voicing strong opposition to on-site treatment and
disposal, the alternative initially proposed by the Navy for the Parcel B contaminated soils. In response
to community concerns, the Navy has selected excavation and off-site disposal for the Parcel B
contaminated soils.
Because the remedy may result in hazardous substances remaining in soil and groundwater at
concentrations above risk-based levels, the 5-year review under CERCLA Section 121(c) will apply to
this action.
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Michael McClellauG Date
BRAC Environmental Coordinator
Hunters Point Shipyard
tiff?
DanielOpaJski / Date/'
Chief
Federal Facilities Cleanup Branch
U.S. Environmental Protection Agency Region IX
Anthony J. Land/s.^.EL/ Date
Chief
Northern California Operations
Office of Military Facilities
California Department of Toxic Substances Control
?- 97
Loretta Barsamian Date
Executive Director
California Regional Water Quality Control Board
San Francisco Bay Region
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2.0 DECISION SUMMARY
2.1 SITE NAME, LOCATION, AND DESCRIPTION
HPS is located on a promontory in southeast San Francisco (Figure 1). The promontory is bounded on
the north and east by the San Francisco Bay and on the south and west by the Bayview-Hunters Point
district of the City of San Francisco. The entire HPS covers 936 acres: 493 on land and 443 under water.
To facilitate the environmental investigation and remediation as well as the ultimate transfer of the
property, HPS was divided into several parcels (Parcels A through F) (Figure 2). This ROD addresses
the remedy for Parcel B.
Parcel B is bounded by other parcels of HPS (Parcels A and C) to the south, the City of San Francisco
Bayview-Hunters Point district to the west, and San Francisco Bay to the north and east. Parcel B covers
approximately 63 acres. Historically, Parcel B was used predominantly for office and commercial
buildings and light industrial production. Under the local reuse authority's current land use plan, upon
transfer of the property by the Navy, Parcel B will be used primarily for an industrial complex, an
educational complex, a mixed residential/retail complex, and a cultural/historical district.
Parcel B is located in the lowlands portion of HPS. Ground surface elevations range from 0 to 18 feet
above mean sea level.
The peninsula forming HPS is within a northwest-trending belt of Franciscan bedrock. The geology of
Parcel B consists primarily of bedrock-derived Artificial Fill. Throughout Parcel B, Industrial Fill and
Undifferentiated Upper Sand Deposits occur locally within or beneath the Artificial Fill. Industrial Fill
occurs locally in the western portion of Parcel B. In the northern portion of Parcel B, the Artificial Fill
in the low-lying areas is generally underlain by Bay Mud Deposits. The Bay Mud Deposits are generally
absent in the southern portion of Parcel B next to the 1935 shoreline. In these areas, the Artificial Fill
directly overlies bedrock or Undifferentiated Sedimentary Deposits. Undifferentiated Sedimentary
Deposits are present locally in some areas at Parcel B, such as in the western areas of the site. The depth
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SAN
FRANCISCO
.^FRANCISCO
PACIFIC:^
OCEAN :V\:
HUNTERS POINT SHIPYARD
HUNTERS POINT SHIPYARD
SAN FRANCISCO. CALIFORNIA
FIGURE 1
FACILITY
LOCATION MAP
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BATVTW MUTCH
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HUNTERS POINT SHIPYAFJO
SAN FRANCISCO, CALirOf?MlA
FIGURE 2
HUNTERS POIKT SHIPYARD PARCEL
LOCATION WAP
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to Franciscan Complex Bedrock from the ground surface in Parcel B varies from less than 1 foot in the
southern portion of the parcel to greater than 80 feet in the northern portion of the parcel.
No surface waters exist on Parcel B; however, Parcel B is adjacent to San Francisco Bay. Although past
information indicated the possible existence of a wetland on Parcel B, revaluation of that data indicated
that no wetlands exist on Parcel B. Two aquifers (the A-aquifer and the B-aquifer) and one
water-bearing zone (the bedrock) have been identified at HPS, but only the A-aquifer and the bedrock
water-bearing zone are present throughout Parcel B. The B-aquifer is present in limited areas of Parcel
B; in other areas, it is indistinguishable from the A-aquifer or is absent.
The A-aquifer consists primarily of saturated Artificial Fill, ranging in thickness from 0 to 90 feet below
ground surface (bgs). On Parcel B, A-aquifer groundwater, which ranges from 2 to 15 feet bgs, generally
flows to the north and northeast, toward San Francisco Bay. The bedrock water-bearing zone was
encountered in the southern portion of Parcel B, and groundwater levels range in depth from 4 to 40 feet
bgs.
The Navy and the State agree that neither the A-aquifer nor the bedrock water-bearing zone have been or
are likely to be used for drinking water. However, the Navy and State do not agree on whether the
groundwater meets the definition of a potential drinking water source under the State Water Resources
Control Board (SWRCB) Resolution No. 88-63, "Sources of Drinking Water Policy." That policy
excludes from the definition of a potential drinking water source (1) groundwater where the total
dissolved solids (TDS) exceed 3,000 milligrams per liter (mg/L) and it is not reasonably expected to
supply a public water system, and (2) groundwater that does not provide sufficient water to supply a
single well capable of producing an average, sustained yield of 200 gallons per day (gpd). It is the
Navy's position that neither the A-aquifer nor the bedrock water-bearing zone meet these criteria. The
TDS content of the A-aquifer ranges from 443 mg/L to 28,000 mg/L. In isolated areas where the TDS
content is below 3,000 mg/L, pump tests indicate that a sustained yield of 200 gpd may be possible;
however, any sustained pumping would result in saline bay-water intrusion. TDS levels for groundwater
in the bedrock water-bearing zone range from 355 mg/L to 4,540 mg/L. Groundwater in this zone is only
present in localized fractures, and a sustained yield of 200 gpd is unlikely. Furthermore, a RWQCB draft
staff report concluded that the likelihood that groundwater underlying HPS would be used as a drinking
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water source is low (RWQCB 1996). However, the RWQCB maintains that the groundwater in some
areas on Parcel B meets the definition of a drinking water source because the TDS is below 3,000 mg/L
and some fresh water pumping is possible. Nevertheless, the RWQCB also recognizes that it is highly
unlikely that the water would be used for drinking water purposes.
2.2 SITE HISTORY
2.2.1 Installation Development
HPS was first developed for dry dock use in 1867. The Navy acquired title to the land in. 1940 and began
developing the area for various shipyard activities. In 1942, the Navy began using HPS for shipbuilding,
repair, and maintenance. From 1945 to 1974, the shipyard was primarily used as a repair facility by the
Navy. The Navy discontinued activities at HPS in 1974, and the shipyard remained relatively unused
until 1976. From July 1, 1976, to June 30,1986, the Navy leased 98 percent of HPS, including all of
Parcel B, to the Triple A Machine Shop (Triple A), a private ship repair company; Triple A did not
vacate the property until March 1987. In 1986, the Navy reoccupied portions of the property.
The Navy used Parcel B for such purposes as office and commercial buildings, warehousing, fuel storage
and distribution, and machining and metal fabrication. Triple A conducted similar activities on Parcel B.
Currently, portions of Parcel B are leased for such uses as artists' studios, storage, and cabinet making.
Most of Parcel B is covered with concrete or asphalt and buildings.
2.2.2 Environmental Investigations
The Navy began environmental studies at HPS in 1984 under the U.S. Department of Defense's IRP, a
program for identifying, investigating, and cleaning up past hazardous waste disposal sites. Between
1984 and 1991, the Navy performed a series of installation-wide investigations, including ambient air
monitoring and radiation investigations, to identify potential sources of contamination at HPS. No air or
radiation concerns were identified on Parcel B. However, 17 areas on Parcel B have been identified as
potential source areas for hazardous substances in soil and/or groundwater. These sites were investigated
under CERCLA. A preliminary assessment/site inspection (PA/SI) was conducted at all sites; fifteen of
the 17 sites were further investigated in a remedial investigation (RI). The 17 sites on Parcel B are
referred to as either SI or IR sites. Sites designated at "SI" sites were investigated through the SI phase at
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which stage the Navy, with regulatory agency concurrence, concluded no additional investigations were
required on these parcels. For completeness, the two SI sites, SI-31 and SI-45, are discussed in the RI.
IR sites were investigated through the RI phase. Table 1 lists the usage of each site by the Navy during
the 1940 to 1974 time frame. Figure 3 shows the location of each of these sites.
In J989, EPA added HPS to the NPL. In 1990, the Navy, EPA Region DC, and the State of California
(through the Department of Toxic Substances Control) entered into a FFA to coordinate environmental
activities at HPS; in 1992, the FFA was modified and the RWQCB became a signatory to the agreement.
In 1991, the U.S. Department of Defense designated HPS for closure as an active military base under its
BRAC program.
2.23 Removal Actions
The Navy is undertaking removal actions at several sites in Parcel B. At IR-06, the former tank farm, the
Navy is excavating approximately 5,400 cubic yards of soil contaminated with organic compounds,
metals, and petroleum hydrocarbons and either disposing of the soil off site (approximately 2,600 cubic
yards) or treating the soil using bioremediation (approximately 2,800 cubic yards) as part of a treatability
study. This removal action has been partially completed, with the exception of excavation of soil in area
A-l, which will be remediated to groundwater as part of the remedial action documented by this ROD.
The remaining contaminated soil has been removed and confirmation sampling has been performed.
Additional groundwater sampling for the A-aquifer and bedrock water-bearing zone will be performed as
part of the data gaps sampling for the Parcel B remedial design. The Navy has excavated soil at discrete
locations in IR-23 and IR-26 as part of a nontime-critical removal action, referred to as the exploratory
excavation (EE) removal action. At IR-23, approximately 854 cubic yards of soil, containing primarily
heavy metals, were excavated from three locations (EE-01, EE-02, and EE-03). EE-01 was excavated to
a depth of 3 feet bgs; EE-02 was excavated to a depth of 6 feet bgs; a portion of EE-03 was excavated to
groundwater depth of 9.5 feet. At IR-26, approximately 817 cubic yards of soil containing solvents,
petroleum related compounds, and metals were excavated from two locations (EE-04 and EE-05) to a
depth of 7.5 feet. Portions of EE-04 and EE-05 were excavated to groundwater depth (7.5 feet).
Confirmation sampling has been performed for the EE removal action. All the EE areas were excavated
to remedial action or ambient metals concentrations, with the exception of portions of EE-03 and EE-05.
At EE-03, total petroleum hydrocarbons (TPH) as diesel was detected at 1,250 milligrams per kilogram
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TABLE 1
PARCEL B SITE DESCRIPTIONS
gH|
SHI
IR-06*
IR-07
IR-10
IR-18
IR-20
IR-23*
IR-24
IR-26*
SI-31
IR-42
SMS
IR-46
IR-50*
IR-51
IR-60
IR-61
IR-62
mMHUffMUMHMSK^fKl^^^S^^^PM^^^e^m
Former Buildings 1 1 1 and 1 12; and Tank Farm
B5B
BBHEI^BMWBil^^HwBKHB
Sub-Base Area
Building 123, Battery and Electroplating Shop
Waste Oil Disposal Area
Building 156, Rubber Shop
Building 146, Tactical Air Navigation (TACAN) Facility; Building 161
Service; Building 162, Paint Storage; and Tank S-136
, Maintenance
Building 124, Acid Mixing Plant; Building 125, Submarine Cafeteria; and Buildings 128
and 130, Machine Shop
Building 157, Nondestructive Testing Laboratory; and Area XIV
Building 1 14, Offices
Building 109, Police Station; Building 1 13, Tug Maintenance Shop and
Shop; and Building 1 13 A, Machine Shop, Torpedo Maintenance Shop,
Shop, and Electrical Substation
Salvage Divers
Tug Maintenance
Steam Line System"
Fuel Distribution Line and Tank Farmb
Storm Drain and Sanitary Sewer Systems6
Former Transformer Sites'*
Dry Docks 5, 6, and 7
Building 122, Electrical Substation V and Compressor Plant
Buildings 1 15 and 116, Submarine Training Buildings and School
Notes:
"IR" refers to sites that were investigated during the remedial investigation. "SI" refers to sites investigated through
the site inspection phase
Only utility lines, distribution lines, and transformer sites located within Parcel B were investigated during the Parcel B
Rl
IR sites with removal actions in progress or completed
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ENGINEERING FIELD ACTIVITY
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(mg/kg) in a confirmation sample at 4.5 feet bgs, beneath the piping connecting to the dispenser of a
former aboveground storage tank; this site was not excavated any further due to physical constraints. At
EE-05, concentrations for arsenic and mercury (13.8 mg/kg and 6.8 mg/kg) were above remedial action
target cleanup levels at 7.5 feet bgs, the depth of groundwater. The contaminated soils were disposed of
off site, and the Navy has restored the areas to preexisting surface conditions. The exploratory
excavation construction summary report is expected to be completed by the end of 1997 (IT 1997). The
Navy has also conducted a nontime-critical removal action that involved removing contaminated
sediments in the storm drain system (IR-50). A total of approximately 200 cubic yards were removed
from 10,500 linear feet of Parcel B storm drains and were disposed of off site. Those removal actions
which left contamination in place, that were above cleanup levels as noted in Table 8 of this ROD above
the groundwater table, will be excavated as part of the remedial action for this parcel. The remaining
removal actions are consistent with the final remedy for Parcel B. Once the removal actions occurring on
Parcel B are complete, appropriate documentation will be included in a future ROD; either a parcel ROD
or a base-wide ROD; should one be negotiated.
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
In the late 1980s, the Navy formed a technical review committee (TRC) consisting of community
members and regulatory agency representatives. The TRC met to discuss environmental issues
pertaining to HPS. In 1993, pursuant to the Defense Environmental Restoration Program, Title 10 of the
United States Code (U.S.C.) Section 2705(d), the Navy formed a Restoration Advisory Board (RAB),
which replaced the TRC. The RAB is composed of members of the community, the Navy, and the
regulatory agencies. The RAB meets monthly to discuss environmental progress at HPS.
The draft final RI report for Parcel B was released to the public in June 1996 (PRC 1996a) and the draft
final FS report was released in September 1996 (PRC 1996b). The proposed plan for Parcel B was
released to the public on October 16, 1996. The RI, the FS, and the proposed plan were made available
to the public in the administrative record and in information repositories at the City of San Francisco
Main Library and the Anna E. Waden Branch Library. In addition, a fact sheet describing the proposed
plan was mailed to the more than 1,100 people on the HPS mailing list. A notice of availability of the
proposed plan was published in The San Francisco Chronicle on October 24, 1996, and in The
Independent on October 25, 1996. The public comment period on the proposed plan began on October
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24, 1996, and was originally scheduled to end on November 25, 1996. At the request of the community,
the 30-day public comment period was extended through December 26, 1996. A notice of the extension
of the public comment period was published in The Independent on November 26, 1996, and in The New
Bayview on December 6, 1996.
A public meeting was held on November 13, 1996. At that meeting, representatives of the Navy
presented the preferred alternative and were available to answer questions about the plan. A response to
comments received at the public meeting and during the public comment period is included in the
Responsiveness Summary, Appendix B of this ROD. These community participation activities fulfill the
requirements of Section .113(k)(2)(B)(i-v) and Section 117(a)(2) of CERCLA.
2.4 SCOPE AND ROLE OF THE RESPONSE ACTION
HPS is a large federal facility containing several potential source areas. To facilitate the investigation,
remediation, and property transfer process under BRAC, sites on HPS have been grouped into Parcels A
through F. The Navy, EPA Region DC, and the State of California have signed a ROD for Parcel A; that
ROD determined that no action was necessary at Parcel A because the site did not pose a potential threat
to human health and the environment. This ROD documents the remedy for Parcel B. Parcel B
originally included IR-25; alternatives developed and evaluated in the FS and the preferred alternative in
the proposed plan included IR-25. However, due to concerns about the long-term impacts of dense non-
aqueous phase liquid (DNAPL) in groundwater at that site, the Parcel B boundaries were re-configured
and the Navy is evaluating additional remedial alternatives for IR-25. Thus, IR-25 has been incorporated
into Parcel C. As a result, the remedy for IR-25 will be proposed in the proposed plan for Parcel C and
selected in the Parcel C ROD. Under the current FFA schedule, the remaining parcels to be addressed by
RODs are as follows:
Parcel Designation Final ROD Approval Date
Parcel C September 1998
Parcel D January 1998
Parcel E October 1998
Parcel F January 1999
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The Navy is also preparing a CAP, with the concurrence of the RWQCB, to address sites contaminated
only with petroleum substances. Petroleum substances are not defined as hazardous substances under
CERCLA. The Navy's goal is to coordinate the activities for the CERCLA sites and petroleum-only sites
to develop a single, coordinated cleanup strategy for Parcel B.
2.5 PARCEL B SITE CHARACTERISTICS
The RI was conducted from 1991 to 1996 to evaluate the nature and extent of contamination on Parcel B
and the related potential human health and ecological risks. Over the course of the RI, the Navy
collected extensive soil, ground water, and utility line data at the 17 sites on Parcel B. The following
samples were collected:
450 surface soil samples from 0 to 2 feet bgs
1,300 subsurface soil samples from deeper than 2 feet bgs at more than 330 soil boring
locations
500 groundwater samples from 93 monitoring wells
120 HydroPunch and grab groundwater samples
35 water and sediment samples from utility lines
Based on the past site uses at the particular site from which the sample was taken, samples were analyzed
for one or a combination of the following: inorganic compounds, pesticides, polychlorinated biphenyls
(PCB), semivolatile organic compounds (SVOC), volatile organic compounds (VOC), petroleum-related
compounds, and gross radiation.
The compounds most often detected in soil and groundwater were petroleum-related compounds,
primarily TPH such as diesel and motor oil, which are not hazardous substances as defined under
CERCLA. However, at most sites on Parcel B, petroleum compounds are commingled with CERCLA
hazardous substances. Areas of commingled contaminants are addressed in this ROD.
At several sites, inorganic compounds were detected at concentrations above ambient concentrations.
Most significantly, at IR-07, referred to as the Sub-Base Area, and IR-18, the Waste Oil Disposal Area,
lead was detected in soil samples at concentrations of 5,120 mg/kg and 2,380 mg/kg, respectively.
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Nickel was also detected at IR-07. The highest nickel concentration in groundwater was 7.1 mg/L and
3,550 mg/kg in soil.
Organic compounds were detected in soil and groundwater samples at IR-10, the former battery and
electroplating shop. A maximum concentration of 980 mg/kg TCE was detected in soil at IR-10. The
highest TCE concentration detected in a groundwater sample from IR-10 was 45 micrograms/liter (|ig/L).
A grab groundwater sample had a TCE concentration of 750 Hg/L and vinyl chloride at 5 Hg/L, however
no additional vinyl chloride has been detected at this site.
Contamination has also been detected outside the HPS boundaries near IR-07 and IR-18. The extent of
contamination, as well as the source of the contamination, has not been determined.
Appendix A contains information on the range of hazardous substances detected at each Parcel B site. A
comprehensive discussion of the nature and extent of contamination on Parcel B appears in Section 4.0 of
the RI report (PRC 1996a). A few minor data gaps have been identified within the Parcel B remedial
investigation and field sampling will be collected during the remedial design phase to allow the remedial
design to adequately address any required remedial action.
2.6 SUMMARY OF SITE RISKS
As part of the RI (PRC 1996a), the Navy evaluated the potential risks to current and future human
receptors from exposure to hazardous substances in soil and groundwater. In addition, the Navy has
conducted a qualitative ecological risk assessment. The results of the human health and ecological risk
assessments are summarized below and are described in detail in Appendix N of the RI report
(PRC 1996a).
2.6.1 Human Health Risk Assessment
The human health risk assessment (HHRA) was performed in accordance with EPA and Cal/EPA-DTSC
guidance for conducting risk assessments (EPA 1989; DTSC 1992).
A critical component of the HHRA process is to identify the pathways through which exposure could
occur as well as the areas of exposure. Currently, Parcel B is used for light industrial purposes. In the
17
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future, after the property is transferred from Navy possession, it could potentially be used for both
industrial and residential purposes. For this reason, the HHRA evaluated exposure pathways for both
industrial and residential scenarios. Under the current industrial scenario, the HHRA assumed that
workers could be exposed by
Ingestion of, dermal contact with, and inhalation of hazardous substances in surface soils
from 0 to 2 feet bgs
Inhalation of fugitive dusts containing hazardous substances or inhalation of vapors that
have volatilized from soil
Inhalation of vapors from A-aquifer ground water entering existing structures
Under the future scenarios, residents and workers could be exposed by:
Ingestion of, dermal contact with, and inhalation of hazardous substances in soil from 0
to 10 feet bgs
Ingestion of bedrock water-bearing zone groundwater
Inhalation of vapors from A-aquifer groundwater entering existing or newly constructed
buildings
In addition, the HHRA assumed that future residents could be exposed to chemicals from dermal contact
with and inhalation of vapors from the bedrock water-bearing zone groundwater, and from consumption
of produce grown in Parcel B soil in quantities up to 94 and 64 pounds annually for adults and children,
respectively.
Under the current scenario, risks were calculated only for the five IRP sites where soil is currently
exposed. For the future scenarios, risks were evaluated for 12 of the 17 sites on Parcel B, regardless of
whether the soil is currently exposed. Risks were not evaluated for SI-31 because, during the SI, the
Navy concluded that no contamination was present at this site. The HHRA also did not evaluate risks for
SI-45 (steam lines), IR-46 (fuel distribution line and tank farm), IR-50 (storm drains and sanitary sewers),
and IR-51 (former transformer sites), all of which are installation-wide sites. Instead, data from samples
collected from these utilities and transformer locations were incorporated into the HHRA for the IRP site
in which the sample was collected.
18
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For the industrial scenarios, exposures were quantified based on a 0.5-acre exposure area. Under the
future residential scenario, the exposures were assessed based on a 2,500-square-foot exposure area, the
size of a typical residential lot in San Francisco. Within these exposure areas, potential site-specific soil
and groundwater exposure point concentrations that are representative of exposure concentrations to
chemicals throughout the exposure area were determined. The potential risks from exposure to site
contaminants were then calculated under average exposure and reasonable maximum exposure (RME)
cases using conservative assumptions. For example, for the RME case, following EPA guidance, the risk
assessment assumed that a resident may be exposed to a chemical 24 hours a day, 365 days a year, for a
30-year period, even though typical exposure to the chemical may be far less.
At HPS Parcel B, the risks and hazards were calculated for each exposure area and discussed in the
HHRA for the IRP site in which the exposure area is located or in contact with. The calculated risks are
presented as probabilities for carcinogens, and as hazard quotients (HQ) for noncarcinogens. For
carcinogens, the risk for an exposure area, referred to as an excess lifetime cancer risk (ELCR),
represents the possibility that one additional occurrence of cancer will result from exposure to
contamination at that exposure area. A risk of 1 in 1,000,000 (which is expressed as 1 x 10"6) means that
1 person in a population of 1,000,000 exposed under the same conditions and time period could develop
cancer as a result of exposure. The American Cancer Society estimates that 1 out of 3 people normally
develops some form of cancer for reasons related to lifestyle, genetics, diet or other factors not related to
exposure to hazardous waste site contamination, resulting in a normal average of about 330,000 people in
a population of 1,000,000 developing cancer. If the risk caused by living at a site such as Parcel B (in its
current condition) is 1 in 1,000,000, the risk of cancer is increased by 1 person and the number of people
potentially developing cancer over a lifetime is 330,001 instead of 330,000. Under Section 300.430(e) of
the NCP, acceptable exposure levels are generally levels that represent a hypothetical excess
upper-bound lifetime cancer risk between 10"* and 10"6 or less. Section 300.430(e) of the NCP also states
that the 10"6 risk level shall be used as the point of departure for determining remediation goals for
alternatives when applicable or relevant and appropriate requirements (ARAR) are not available or are
not sufficiently protective.
For noncarcinogens, the effects of a single contaminant in a single medium is expressed as the HQ, the
ratio of a single exposure level (that is, the estimated quantity of the contaminant that an individual
would be exposed to under a given pathway) over a specified time period to a reference dose for that
19
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substance derived from a similar exposure period. The segregated hazard index (HI) is the sum of the
HQs for multiple substances, or for a single substance over multiple pathways, for a specific target organ.
A segregated HI greater than 1.0 indicates the potential for adverse health effects, but does not mean that
an adverse health effect is certain. It is a benchmark value indicating a greater probability for a possible
adverse effect.
In two instances, ELCRs and His were not calculated. Instead, in the first instance, to evaluate the
potential volatilization of chemicals of potential concern in A-aquifer groundwater, movement through
soil and into indoor air spaces was modeled. The estimated air concentrations were compared to EPA
Region IX preliminary remediation goals (PRO) for ambient air (EPA 1995). The PRGs use RME values
for a residential scenario to estimate concentrations in environmental media that correspond to an ELCR
of 10"6 or an HI of I. Second, potential risks associated with lead were evaluated by comparing Parcel B
soil data to either EPA Region DC soil PRGs, under the industrial scenario, or to EPA and DTSC blood-
lead concentration model results, under the future residential scenario. Detailed descriptions of the
approaches used are provided in Appendix N of the RI report (PRC 1996a).
The HHRA found that the primary risks and hazards associated with HPS Parcel B relate to future
industrial or residential exposure through ingestion of and dermal contact with contaminated soils (PRC
1996a). In addition, under the future residential scenario, ingestion of produce grown at the site also
contributes to the risks and hazards associated with HPS Parcel B. The range of soil ELCRs and
segregated His for exposure areas within an IRP site and the soil lead evaluation are presented in Tables
2, 3, and 4 for the current industrial, future industrial, and future residential scenarios, respectively.
Figure 4 shows the 2,500-square-foot areas within which the HHRA calculated a potential cancer threat
to future residents above Iff6 or a segregated noncarcinogenic hazard greater than 1 for soil, based on
RME assumptions.
For the reasons set forth in Section 2.1 and in Sections 3.8 and 3.9 of the RI report (PRC 1996a),
groundwater contamination is unlikely to pose a threat to human health. Nevertheless, A-aquifer and
bedrock water-bearing zone groundwater were evaluated in the HHRA. Specifically, the HHRA assumed
20
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TABLE 2
IR-07
HUNTERS POINT SHIPYARD PARCEL B
POTENTIAL RISKS UNDER CURRENT INDUSTRIAL EXPOSURE SCENARIO'
6x 10"to5x 10
5 x 10"'to 4 x 10
<1
< 1
Aroclor 1260, Beryllium, Benzo(a)pyrene
IR-18
1 x 10" to2x 10"
8x 10-" to 2 x 10'"
< 1
-------
TABLE 3
HUNTERS POINT SHIPYARD PARCEL B
POTENTIAL RISKS UNDER FUTURE INDUSTRIAL EXPOSURE SCENARIO
IR-06
soil"
6x I0yto2x 10"
Yes
Aroclor 1260, Arsenic,
Benzo(a)pyrene,
Benzo(h)fluoranthene,
Benzo(k)fluoranthene.
Benzene, Beryllium
groundwater
2x 10'°to3x 10"
2x I03to2x
-------
TABLE 3 (Continued)
HUNTERS POINT SHIPYARD PARCEL B
POTENTIAL RISKS UNDER FUTURE INDUSTRIAL EXPOSURE SCENARIO
IR-26
soil
5x I
-------
TABLE 4
1R-06
HUNTERS POINT SHIPYARD PARCEL B
POTENTIAL RISKS UNDER FUTURE RESIDENTIAL EXPOSURE SCENARIO
Aroclor 1260, Benzo(a)anthracene,
Benzo(a)pyrene, Benzo(b)fluoranthenc,
Benzo(k)fluoranlhene, Chrysene,
Beryllium, Nickel, Antimony
groundwater
I x 10s to 2 x I(T
8x I05to8x
to 7.4
to 19
N/A
Arsenic, Chromium, Vinyl Chloride,
Carbon Tetrachloride
IR-07
soil
7x 10 to 4 x 10"
3x 10'to 2 x
< I to 2.0
to 9.0
Yes
Benzo(a)pyrene, Benzo(a)anthracene,
Benzo(b)f1uoran(hene, Arsenic, Beryllium,
Chrysene, Nickel, Antimony
IR-10
soil
I x 108to5x 105
I x I07to7x 10
to 10
to 38
Yes
Trichloroethene, Beryllium, Arsenic,
Benzo(a)pyrene
IR-18
soil
2* 10"to2x
2 x I07to 3 x 103
to 19
to 85
Yes
Aroclor 1260, Aroclor 1254, Arsenic,
Bcnzo(b)fluoran(hene,
Benzo(k)fluoranthenc, Bcnzo(a)pyrenc,
Beryllium, Nickel, Chrysene
IR-20
soil
6x 10"to2x
3x I0rlo8x 105
to I.I
to 3.9
Yes
Aroclor 1260, Nickel, Manganese
1R-23
soil
2x 108to2x 10
8x 108to3x
to 2.8
to 8.6
Yes
Aroclor 1260, Arsenic, Benzo(a)pyrene,
Beryllium, Tetrachloroethcne
groundwater
7 x 10'
4x 105
22
32
No
Arsenic, Manganese, Nickel
IR-24
soil
7x I0'°to6x
4 x 10^6 x 103
to 2.9
to 6.9
Yes
Aroclor 1260, Aroclor 1242, Arsenic,
Benzo(a)pyrene, Benzo(b)fluorathene,
Manganese
groundwater
I x 10s
8x 10s
-------
TABLE 4 (Continued)
HUNTERS POINT SHIPYARD PARCEL B
POTENTIAL RISKS UNDER FUTURE RESIDENTIAL EXPOSURE SCENARIO
Site
Name
IR-26
Medium
Total ELCR Range'
COPCs Contributing SI
Risk aria/or H"
Arsenic, Aroclor 1260, Beryllium,
Benzo(b)fluoranthene,
Benzo(k)fluoranthene, Manganese
IR-42
soil
7 x I08 to 3 x 10°
4 x 10 ' to3x 1
-------
SAN FRANCISCO BAY
ENCINCERING FiaO ACTIVITY WEST
r~| rorrwrui e*«eMeetMe nsx trcnw tec-e* e*
tOI«i HfiKTOATR) N
4
PARCa B
CRO AREAS W WHICH POTENTIAL
CARCMOGEWC RISK EXCEEDS IOC-06
OR TOTAL SEGREGATED HI EXCEEDS t
RESBENTIAL SCENARIO
-------
that people may ingest, inhale, or come into physical contact with water from the bedrock water-bearing
zone. The ranges of ELCRs and segregated His for bedrock water-bearing zone exposure areas within
each IRP site are presented in Tables 3 and 4 for the future industrial scenario and the future residential
scenario, respectively. For A-aquifer groundwater, the only potential pathway is volatilization of
chemicals into indoor air. Based on the modeling of A-aquifer groundwater data, groundwater in sites
IR-06, IR-10, and IR-24 (in the vicinity of IR-10) indicate a potential threat to future residents in a
localized area of Parcel B. However, this risk is likely overestimated based on VOC emission flux rate
measurements from the exposure area with the highest A-aquifer groundwater VOC concentrations.
Indoor air concentrations based on the measured emission flux rates were all below ambient air PRGs
and were significantly lower than the indoor air concentrations calculated from groundwater VOC
concentrations.
2.6.2 Ecological Risk Assessment
Approximately 75 percent of Parcel B is developed and covered by manmade structures such as roads
and buildings. With little open space for flora and fauna, Parcel B is considered to have insignificant
habitat value. Exposure pathways to terrestrial species are incomplete because of the lack of habitat and
predominance of paved areas. As a result, Parcel B does not pose a risk to terrestrial receptors.
Concentrations of hazardous substances in groundwater migrating to San Francisco Bay are below
NAWQC and water quality objectives (taking into account dilution and ambient metal concentrations),
except at IR-07. Compounds exceeding NAWQC at IR-07 include metals such as nickel, and SVOCs;
mitigative measures such as source removals and post-remediation groundwater monitoring for four
quarters will be implemented to address potential threat to aquatic receptors. Therefore, with the
possible exception of IR-07, the groundwater impacted with CERCLA substances does not pose a threat
to aquatic receptors. Potential risks to aquatic receptors posed by petroleum substances are being
evaluated separately under the Parcel B CAP. However, because sediment in storm drains may pose a
threat to aquatic receptors, the storm drains have been cleaned out as part of a removal action, as
discussed in Section 2.2.3. Any appropriate response actions to address past releases from Parcel B that
may have impacted aquatic receptors will be considered in the Parcel F FS and ROD.
27
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2.7 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
This section discusses ARARs for Parcel B at HPS. Under Section 121(d) of CERCLA, remedial actions
that are conducted entirely on site must attain a level or standard of control which complies with ARARs,
unless waived. ARARs are federal environmental laws and more stringent state environmental and
facility siting laws. In addition to being more stringent than federal requirements, state requirements
must also be legally enforceable, consistently enforced statewide, and identified in a timely manner to
qualify as ARARs.
Any portion of a remedial action which takes place off site must comply with all laws legally applicable
at the time the off-site activity occurs, both administrative and substantive. For example, contaminated
soil transported off site must be transported in accordance with applicable Department of Transportation
(DOT) regulations, 49 CFR Parts 171-179.
ARARs may be chemical-specific, location-specific, or action-specific. The ARARs identified by the
Navy are described below. Also discussed below are several state requirements that the State has
asserted are ARARs. The Navy does not agree that all of those requirements are ARARs. The following
discussion identifies those areas of disagreement between the Navy and the State.
Chemical-Specific ARARs
Chemical-specific ARARs are health- or risk-based concentration limits, numerical values, or
methodologies for various environmental media that are established for a specific chemical that may be
present at the site, or that may be discharged to the site during remedial activities. Laws and regulations
that have been identified as potential ARARs for the two media of concern at Parcel B, groundwater and
soil, are discussed below.
Soil
The Navy has not identified any chemical-specific ARARs for soil at Parcel B. However, the State
asserts that SWRCB Resolution No. 92-49 and the Basin Plan are chemical-specific ARARs for soil.
28
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Because Resolution No. 92-49 and the Basin Plan do not contain "health- or risk-based concentration
limits, numerical values, or methodologies" for soil, the Navy disagrees with the State.
Groundwater
The State asserts that SWRCB Resolutions 88-63, 92-49, and 68-16 and the Basin Plan are chemical-
specific ARARs for ground water at HPS Parcel B. Each of these documents is discussed below.
Resolution No. 88-63: As explained in Section 2.1, SWRCB Resolution No. 88-63 defines potential
sources of drinking water, and this definition is relevant in determining appropriate cleanup goals. The
Navy and the State do not agree on whether A-aquifer and bedrock water-bearing zone groundwater meet
the criteria for classification as a potential drinking water source. For the reasons set forth in Section 2.1,
the Navy has determined that neither the A-aquifer nor the bedrock water-bearing zone meet the criteria
in Resolution No. 88-63. While the State believes that the groundwater in both the A-aquifer and the
bedrock water-bearing zone technically is potentially suitable for drinking water use, the State also
recognizes that use is not likely to be realized. Many extreme conditions of water availability within the
San Francisco Bay region would have to change dramatically before the potential use of the water for
drinking would be realized. For this reason, the State concurs that, regardless of whether Resolution
88-63 applies to Parcel B groundwater, cleanup of the water to drinking water standards is neither
applicable nor relevant and appropriate at HPS Parcel B.
Resolution No. 92-49: SWRCB Resolution No. 92-49, adopted pursuant to the Porter-Cologne Water
Quality Act, California Water Code Sections 13304 and 13307, was promulgated by the SWRCB as
policies and procedures to be followed by the RWQCB's for oversight of investigations and cleanup and
abatement decisions. Most of Resolution No. 92-49 contains procedural rather than substantive
requirements and is therefore not an ARAR. Nevertheless, the Navy agrees with the State that Section
III.G, which states that dischargers must abate the effects of the discharges "in a manner that promotes
attainment of either background water quality, or the best water quality that is reasonable," is relevant
and appropriate for groundwater.
Resolution No. 68-16: SWRCB Resolution No. 68-16, adopted pursuant to the Porter-Cologne Water
Quality Act, Water Code Section 13140, is the State's "Statement of Policy with Respect to Maintaining
29
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High Quality Waters in California." The State and the Navy disagree on whether Resolution No. 68-16
is an ARAR. The State asserts that Resolution No. 68-16 is a potential ARAR that governs the further
migration of contaminated groundwater and requires cleanup of groundwater to background levels. The
Navy asserts that Resolution No. 68-16 is prospective in intent, applying to new discharges in order to
maintain existing high-quality waters.
Basin Plan: The Basin Plan, adopted pursuant to the Porter-Cologne Water Quality Act, Water Code
Section 13240, identifies beneficial uses for surface water and groundwater and establishes numerical
and narrative standards to protect those beneficial uses. As described in Section 2.1, the beneficial use of
the groundwater underlying HPS does not include municipal supply for the following reasons:
groundwater has never been used for such purposes, high TDS values in the A-aquifer, likely saltwater
intrusion if pumping should occur, and limited groundwater availability in the bedrock water-bearing
zone. For these same reasons, the Navy and State agree that the groundwater's beneficial uses do not
include industrial service or process supply or agricultural supply. The only possible beneficial use of
the groundwater is freshwater replenishment. The narrative water quality objectives for groundwater as
they relate to freshwater replenishment are applicable; in addition, although not applicable because they
apply to surface water, the numerical water quality objectives in Table 3-3 of the 1995 Basin Plan are
relevant and appropriate to the extent that groundwater migrates into surface water.
Location-Specific ARARs
Location-specific requirements are restrictions placed on the concentration of hazardous substances or
the conduct of activities solely because they occur in special locations. The only location-specific ARAR
is the Coastal Zone Management Act. Under Section 307(c)(l) of the Coastal Zone'Management Act, 16
U.S.C. Section 1456(c), federal activities affecting the coastal zone must be conducted in a manner
consistent with the State's coastal zone management program. California's coastal zone management
plan is found in the California Coastal Act, California Public Resources Code Section 30000 et seq. The
Navy will evaluate the remedial action to ensure consistency with the coastal zone management plan.
Although Pumphouse No. 3 in IR-26 is eligible for inclusion on the National Register, no remedial action
will be undertaken that will affect the pumphouse. Therefore, the National Historic Preservation Act, 16
U.S.C. Section 470 et seq., is not an ARAR for Parcel B.
30
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Action-Specific ARARs
These requirements are technology- or activity-based requirements or limitations on actions taken with
respect to the hazardous substances. Discussed below are the potential action-specific ARARs for the
remedial alternatives considered for Parcel B.
Hazardous Waste Regulations: Regulations adopted pursuant to the California Hazardous Waste Control
Law, Health & Safety Code Section 25100 et seq., are action-specific ARARs common to both the soil
and groundwater alternatives. These requirements will determine how excavated soil and extracted
groundwater must be managed and disposed of. The Navy will analyze samples from excavated soils and
extracted groundwater in accordance with the hazardous waste identification regulations in Title 22 of
the California Code of Regulations (CCR), Division 4.5, Chapter 11, Articles 2-4 (40 CFR Part 261,
Subparts B-D) to determine whether any of the media must be managed as a hazardous waste. If the
media must be managed as hazardous waste, the substantive generator requirements in 22 CCR, Division
4.5, Chapter 12, Articles 1-3 (40 CFR Part 262, Subparts A-C) are applicable. As appropriate, excavated
soil and extracted groundwater will be evaluated in accordance with 22 CCR, Division 4.5, Chapter 18,
Article 1, Section 66268.7(a) (40 CFR Part 268.7(a)) to determine whether they are subject to land
disposal restrictions.
Several of the soil and groundwater alternatives considered for Parcel B involve on-site treatment. If
data indicate that the excavated soil or extracted groundwater contain a listed waste or concentrations of
hazardous substances above the hazardous waste characteristic levels in 22 CCR, Division 4.5, Chapter
11 (40 CFR Part 261), the substantive requirements for miscellaneous units in 22 CCR, Division 4.5,
Chapter 14, Article 16 (40 CFR Part 264 Subpart X) are potentially relevant and appropriate to the
treatment unit. In addition, the standards for process vent requirements in 22 CCR, Division 4.5, Chapter
14, Article 27 (40 CFR Part 264, Subpart AA) for hazardous waste treatment units are potentially
relevant and appropriate to alternatives involving air stripping.
Air Regulations: Several of the Bay Area Air Quality Management District (BAAQMD) regulations are
ARARs for the soil remedial alternatives. First, substantive requirements in BAAQMD Regulation 6 and
Regulation 8-40 are relevant and appropriate to excavation activities. Specifically, Regulations 6-301,
6-302, and 6-305, which contain particulate and visible emissions standards, are relevant and
31
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appropriate. Regulation 8-40-301, which limits uncontrolled aeration, and Regulation 8-40-303, which
contains requirements for soil storage piles, are also relevant and appropriate to those alternatives that
involve stockpiling soil.
Additional BAAQMD regulations are ARARs for some of the alternatives involving treatment of
contaminated soil or groundwater. Specifically, for those soil alternatives which include soil vapor
extraction (SVE) and those groundwater alternatives which include air stripping, Regulation 8-47 is
applicable. BAAQMD Regulation 8-47 requires implementation of emission controls if the emissions
from an SVE system or an air stripper exceed 1 pound per day of selected VOCs. The BAAQMD has
indicated that Regulation 8-47 is also an ARAR for any alternative that includes thermal desorption.
Finally, for all alternatives which would have air emissions from on-site treatment units, the substantive
requirements in BAAQMD Regulation 2-301, regarding the use of best available control technology
(BACT) for new air emission sources, are relevant and appropriate.
Landfill Closure Regulations: Several of the soil alternatives include use of the soil as sub-base
foundation material at the IR-1/21 landfill in Parcel E, assuming capping is the selected remedy for the
landfill. State requirements for closure of landfills in 14 CCR, Division 7, Chapter 13, and in 23 CCR,
Division 3, Chapter 15, are ARARs for activities conducted at the IR-1/21 landfill. ARARs relating to
the landfill will be fully evaluated as part of the FS for Parcel E. The State has also indicated that these
requirements should be considered as ARARs for alternatives involving on-site capping (i.e.. Alternative
S-8).
SWRCB Waste Discharge to Land Regulations (Chapter 15): In addition to the landfill closure
requirements discussed above, the State has indicated that requirements in 23 CCR; Division 3, Chapter
15 pertaining to waste piles and groundwater monitoring should also be identified as ARARs. Based on
the Navy's review of Chapter 15, the requirements in 23 CCR, Division 3, Chapter 15, Section 2546 on
precipitation and drainage controls are considered relevant and appropriate for those alternatives
involving stockpiling of soil. The State also believes that the detection monitoring requirements in 23
CCR, Division 3, Chapter 15, Section 2550.8 are relevant and appropriate. The Navy disagrees with the
32
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State. Those requirements pertain to establishing background values, proposing monitoring parameters,
and determining whether a statistically significant release has occurred. Background values have already
been established for HPS. Moreover, elsewhere in this ROD, the Navy and the regulatory agencies have
presented the proposed monitoring plan approach. Tables 5 and 6 summarize how the laws, regulations,
and resolutions described above relate to the soil and groundwater alternatives evaluated in the FS and
summarized in Section 2.8 of the ROD.
2.8 DESCRIPTION OF ALTERNATIVES
This section describes the soil and groundwater alternatives evaluated in detail during the FS (PRC
1996b), and presents the cleanup goals selected by the Navy. At the time the FS was prepared, IR-25 was
within the boundaries of Parcel B. However, because of concerns related to DNAPL in that area, the
Navy is evaluating additional remedial alternatives for IR-25. Because DNAPL is also present at IR-28
in Parcel C, the Navy plans to develop and select a remedy for IR-25 as part of the remedy selection
process for Parcel C. For this reason, although the remedial alternatives set forth in the FS included
actions to address contamination at IR-25, those components of the alternatives relating to IR-25 are not
included in the description of alternatives in this ROD. For example, each of the soil alternatives in the
FS included removal of DNAPL from IR-25; however, DNAPL removal is not included in the following
descriptions. The costs and soil volumes have also been changed from the FS to exclude IR-25.
2.8.1 Soil Alternatives
During the FS, the Navy initially evaluated eight remedial alternatives for soil. Based on the initial
screening, six alternatives, including the no-action alternative, were retained for detailed analysis and
comparison. The soil alternatives (excluding the no-action alternative) are summarized in Table 7 below
and described in detail in the following paragraphs.
33
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TABLE 5
ARAKS' FOR SOIL ALTERNATIVES
AltS-1
Alt S-2
Alt S-3
AltS-4
Alt S-6
Alt S-8
Chemical-Specific ARARs
Basin Plan
The Navy and State do not agree that the Basin Plan is an ARAR. However, other than the no action alternative,
all alternatives will, through soil source removal activities, satisfy Basin Plan objectives regardless of whether it's
an ARAR.
SWRCB Resolution No. 92-49
The Navy and State do not agree that Resolution No. 92-49 is an ARAR for the soil alternatives. However, other
than the no action alternative, all alternatives will, through soil source removal activities, satisfy Resolution
No. 92-49.
Action-Specific ARARs
Hazardous waste identification
regulations
[22 CCR, Div. 4.5, Chap. 11, Art.
2-4/40 CFR Part 261, Subparts
B-D]
These
requirements are
not applicable
because no
contaminated
media is
generated.
These requirements are applicable for soil that will be excavated and disposed off site. The
excavated soil would be analyzed to determine appropriate management and disposal
practices.
Generator requirements
[22 CCR, Div. 4.5, Chap. 12, Art.
1-3/40 CFR Part 262, Subparts
A-C]
These
requirements are
not applicable
because no
contaminated
media is
generated.
The substantive generator requirements are applicable if excavated soil exhibits a hazardous
waste characteristic or contains a listed hazardous waste and is being managed in containers
on site for less than 90 days.
34
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TABLE 5 (Continued)
ARAKS' FOR SOIL ALTERNATIVES
Land disposal restrictions
[22 CCR, Div. 4.5, Chap. 18, Art.
1, Sec. 66268.7(a)/40 CFR Part
268.7(a)]
Miscellaneous treatment unit
requirements for hazardous waste
[22 CCR, Div. 4.5, Chap. 14, Art.
16/40 CFR, Part 264, Subpart X]
Control of visible emissions and
participates
(Bay Area Air Quality
Management District Regulation
(BAAQMD) 6-301)
AItS-1
These
requirements are
not applicable
because no
contaminated
media is
generated.
These
requirements are
not ARARs
because this
alternative does
not involve
treatment.
These
requirements are
not ARARs
because no
emissions or
particulates will
be generated.
AltS-2 AltS-3 AltS-4 j
Alt S-6 Alt S-8
These requirements are applicable for excavated soil. Excavated soil would be analyzed to
determine if treatment is required, either on site or by the off-site landfill operator, prior to
disposal.
These These requirements are relevant and appropriate for the treatment unit if
requirements are the excavated soil must be managed as a hazardous waste.
not ARARs
because this
alternative does
not involve
treatment.
These requirements are relevant and appropriate for excavation activities. Appropriate
controls will be in place to control emissions.
35
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TABLE 5 (Continued)
ARAKS' FOR SOIL ALTERNATIVES
Aeration of soil
(BAAQMD Regulation 8-40)
Use of BACT for new sources
(BAAQMD Regulation 2-301)
Emissions requirements for soil
vapor extraction systems
(BAAQMD Regulation 8-47)
Landfill closure requirements
(14 CCR, Div. 7, Chap. 13 and 23
CCR, Div. 3, Chap. 15)
Alt S.I
These
requirements are
not ARARs
because this
alternative does
not involve
excavation of
soil.
Alt S-2
Alt S-3 Alt
S-4 AltS-6
Alt S-8
These requirements are relevant and appropriate for stockpiling of excavated soils.
This requirement is not an ARAR
for Alternatives S- 1 and S-2 because
these alternatives do not involve
treatment.
These requirements are not ARARs
for Alternatives S-l and S-2 because
these alternatives do not involve on-
site treatment.
These requirements are not ARARs
because capping is not a component
of these alternatives.
These requirements are relevant and appropriate for the
treatment units.
These These
requirements are requirerr
applicable to the applicab
SVE unit. SVE uni
BAAQMD
tents are asserts these
le to the requirements
t. would apply to
the thermal
desorption unit
These regulations would be considered in evaluating
potential ARARs for the IR-1/21 landfill.
These
requirements are
not ARARs
because Alt. S-8
does not involve
treatment.
These
requirements are
not applicable
because this
alternative does
not use SVE.
The RWQCB
asserts that the
Chapter 15
requirements
apply to the cap
proposed under
this alternative
36
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TABLE 5 (Continued)
ARARS1 FOR SOIL ALTERNATIVES
Waste discharge to land
requirements
(23 CCR, Div. 3, Chap. 15, Section
2546)
Location-Specific ARARs
Coastal zone management plan
consistency
(Coastal Zone Management
Act, 16 U.S.C. Section 1456(c))
AltS-1
These
requirements are
not applicable
because no
contaminated
media is
generated.
AItS-2 AltS-3 AltS-4 | AltS-6 AltS-8
These requirements would be relevant and appropriate for soil stockpiles. Appropriate
precipitation and drainage controls would be incorporated into the design of the stockpile.
This requirement
is not an ARAR
because this
alternative does
not involve any
action.
This requirement is applicable to the extent that remedial activities take place within the
coastal zone.
Notes:
' As explained in Section 2.7 and this table, the Navy does not agree that all the requirements listed are, in fact, ARARs.
37
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TABLE 6
ARARS* FOR GROUNDWATER ALTERNATIVES
ARAR
Alternative GW-1 | Alternative GW-2 | Alternative GVV-3 | Alternative GW-5
Chemical-Specific ARARs
San Francisco Bay Water Quality
Control Plan
The Navy recognizes that the Basin Plan must be considered to determine the potential
beneficial uses of groundwater at Parcel B as the beneficial use will guide the remedial
goals. The Navy does not believe any beneficial uses for groundwater underlying Parcel
B are present, including freshwater replenishment. By removing the sources and
monitoring, the State agrees that Alternative GW-2 satisfies the Basin Plan goals with
respect to freshwater replenishment. Alternatives GW-3 and GW-5 would also satisfy
these goals.
SWRCB Resolution No. 88-63,
Sources of Drinking Water Policy
The Navy and the State do not agree on whether groundwater underlying Parcel B meet
the criteria as a potential drinking water source. Nevertheless, the Navy and State agree
that drinking water standards are neither applicable nor relevant or appropriate for Parcel
B.
SWRCB Resolution No. 92-49,
Policies and Procedures for
Investigation and Cleanup and
Abatement of Discharges under
Water Code Section 13304
Section III.G of Resolution No. 92-49, which requires dischargers to abate the effects of
discharges "in a manner that promotes attainment of either background water quality, or
the best water quality that is reasonable," is relevant and appropriate. By removing the
source (i.e., the soil), all of the groundwater alternatives, except GW-1, will promote the
only possible beneficial use of groundwater (i.e., freshwater replenishment)
SWRCB Resolution No. 68-16,,
Statement of Policy with Respect
to Maintaining High Quality
Waters in California
As discussed in Section 2.7 of this ROD, the Navy and the State disagree as to whether
Resolution No. 68-16 is an ARAR. With the exception of GW-1, the State believes that
by removing source areas and continued monitoring, Alternatives GW-2, GW-3, and
GW-5 would meet the requirements of Resolution 68-16 regardless of whether it is an
ARAR
38
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TABLE 6 (Continued)
ARARS* FOR GROUNDWATER ALTERNATIVES
ARAR
Alternative GW-1 | Alternative GVV-2 | Alternative GW-3 | Alternative GW-S
Action-Specific ARARs
Hazardous waste identification
regulations
(22 CCR, Div. 4.5, Chap. 11. Art.
2-4/40 CFR Part 261, Subparts
B-D)
These requirements are not ARARs for
Alts. GW-1 and GW-2 because these
alternatives do not result in the generation
of contaminated media.
These requirements are applicable to
Alternatives GW-3, and GW-5. Extracted
groundwater would be analyzed to
determine appropriate management and
disposal practices.
Generator requirements
(22 CCR, Div. 4.5, Chap. 12, Art.
1-3/40 CFR Part 262, Subparts
A-C)
These requirements are not ARARs for
Alts. GW-1 and GW-2 because these
alternatives do not result in the generation
of contaminated media.
These requirements would be applicable if
extracted groundwater exhibits hazardous
waste characteristics and is shipped off
site.
LDR regulations
(22 CCR, Div. 4.5, Chap. 18, Art.
1, Sec. 66268.7(a)/(40 CFR Part
268.7(a))
These requirements are not ARARs for
Alts. GW-1 and GW-2 because these
alternatives do not result in the generation
of contaminated media.
These requirements are applicable if
extracted groundwater must be managed
as a hazardous waste and is shipped off
site for disposal.
39
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TABLE 6 (Continued)
ARARS1 FOR GROUNDWATER ALTERNATIVES
ARAR
Miscellaneous treatment unit
requirements for hazardous waste
(22 CCR, Div. 4.5, Chap. 14, Art.
1 6/40 CFR. Part 264 Subpart X)
Air stripping emissions
requirements
(BAAQMD Regulation 8-47)
Alternative GYV-1 | Alternative G\V -2
These requirements are not ARARs for
Alts. GW-1 and GW-2 because these
alternatives do not involve treatment.
These requirements are not ARARs for
Alts. GW-1 and GW-2 because these
alternatives do not involve treatment.
Alternative GW-3
These requirements
are relevant and
appropriate for the
air stripping unit if
the extracted
groundwater
exhibits hazardous
waste
characteristics.
These requirements
are applicable to the
air stripper. The air
stripper would be
operated in
accordance with
these requirements.
Alternative GVV-5
These requirements
are not ARARs
because Alt. GW-5
does not involve
treatment.
These requirements
are not ARARs
because Alt. GW-5
does not involve
treatment.
40
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TABLE 6 (Continued)
ARARS1 FOR GROUNDWATER ALTERNATIVES
ARAR
Air emissions for process vents
from hazardous waste treatment
units
[22 CCR, Div. 4.5, Chap. 14, Art.
1 6/40 CFR Part 264, Subpart AA]
Location-Specific ARARs
Coastal zone management plan
consistency
(Coastal Zone Management
Act, 16 U.S.C. Section 1456(c))
Alternative GVV-1
Alternative GW-2
These requirements are not ARARs for
Alts. GW-1 and GW-2 because these
alternatives do not involve treatment.
Alternative GYV-3
These requirements
may be relevant and
appropriate for the
air stripper
depending on the
concentrations of
hazardous
substances in the
extracted
groundwater.
Alternative GVV-5
These requirements
are not ARARs
because Alt. GW-5
does not involve
treatment.
This requirement is
not an ARAR
because this
alternative does not
involve any action.
This requirement is applicable to the extent that remedial
activities take place within the coastal zone.
Notes:
1 As explained in Section 2.7 and this table, the Navy does not agree that all the requirements listed are. in fact, ARARs.
41
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TABLE 7
COMPONENTS OF SOIL ALTERNATIVES
Remedy Component
Off-Site Management
On-Site Soil Vapor Extraction
On-Site Thermal Desorption
On-Site Asphalt Encapsulation or Solidification and
Stabilization
Use of Excavated Soil for the IR-1/21 Landfill Cap
Foundation
Placement of Treated Soils
Capping
Alternative
S-2
X
S-3
X
X
X
S-4
X
X
X
X
S-6
X
X
X
X
X
S-8
X
X
42
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Several elements are common to all of the alternatives (excluding the no-action alternative). Common
elements include the cleanup goals for soil remaining on Parcel B and off-site management options for
contaminated soil. These common elements are described below.
The remedial action objective for soil is to prevent ingestion of, direct dermal contact with, or inhalation
of hazardous substances in soil. To achieve this objective, the FS considered different soil cleanup goals
corresponding to carcinogenic risks of 10"4, 10"5, and 10"6 under both future industrial and future
residential scenarios. Although only certain portions of Parcel B are slated for residential use under the
current reuse plan, the Navy proposes to clean up the entire parcel to residential risk-based standards. As
explained in Section 2.6.1, the NCP establishes an acceptable risk range of 10"4 to 10"6 and a point of
departure for remedial alternatives of 10"* for carcinogens. The Navy has chosen to set its cleanup goal
at the lower end of the risk range, which is more protective of human health. In short, the Navy has
established the following cleanup goals for soil remaining on Parcel B:
Excess lifetime cancer risk of 10"6 or less for carcinogens, except where ambient
concentrations of inorganic compounds exceed 10"6 because of the fill material
HI of 1 or less for noncarcinogens, except where ambient concentrations of inorganic
compounds exceed an HI of 1 because of the fill material
Lead levels of less than 221 mg/kg
Chemical-specific cleanup goals for soil remaining on Parcel B were calculated to correspond to a risk
level of 10"6 or an HI equal to 1. These cleanup goals are listed in Table 8. However, because of the
limits of analytical methodologies, it may not be possible to achieve some of these cleanup goals; for
those compounds, the cleanup goal is the detection limit.
With the exception of the no-action alternative (Alternative S-l), the soil alternatives rely to some extent
on management of excavated soil at off-site facilities. The management options available for
contaminated soil depend on the regulatory requirements for hazardous waste set forth in 22 CCR,
Division 4.5. Soil management options that would apply to each of the alternatives are identified on
Table 9.
Based on the analytical data gathered during the RI (PRC 1996a), the Navy anticipates that the majority
of excavated soil would be suitable for landfill disposal. Analytical testing of the soils will be conducted
43
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TABLE 8
SOIL CLEANUP STANDARDS
L;.~<«:' -'--' .- --ft-i- if. ''**- -; Si ; S:'j .,'si' £'1 i-,r v .#Jii'vu ,:: ^Jh£ffiTVT-if>^t7rtrS^^ff &*"'';' ' tvi (,-'. «-v-s-J 1
Volatile Organic Compounds
Benzene
Bromoform
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chloroform
1 ,2-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene (total)
cis- 1 ,2-Dichloroethene
trans- 1 ,2-Dichloroethene
Ethylbenzene
Freon 113
Methyl ethyl ketone
Methyl isobutyl ketone
Styrene
Tetrachloroethene
Toluene
1,1,1 -Trichloroethene
1 , 1 ,2-Trichloroethene
Trichloroethene
Vinyl acetate
Vinyl chloride
Xylene (total)
0.035
0.081
12.7
0.074
21.5
0.051
0.019
0.007
9.1
8.8
22.8
227.6
13,334.7
62.1
27.3
313.9
0.161
231.9
12.0
0.030
0.271
62.3
0.002(0.01)
888.5
Semivolatile Organic Compounds
Acenaphthene
Acenaphthylene
Anthracene
B enzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
141.1
130.1.
967.9
0.117
0.016(0.33)
0.030
44
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TABLE 8 (Continued)
SOIL CLEANUP STANDARDS
mm^mzsK^w&amasx
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Benzoic acid
Carbazole
Chrysene
Dibenzo(a,h)anthracene
Dibenzofuran
1 ,2-Dichlorobenzene
1 ,4-Dichlorobenzene
Diethylphthalate
2,4-Dimethylphenol
Fluoranthene
Fluorene
Indeno( 1 ,2,3-cd)pyrene
2-Methylnaphthalene
N-Nitrosodiphenylamine
N-Nitrosodipropylamine
Naphthalene
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
1 ,2,4-Trichlorobenzene
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Trivalent Chromium
Hexavalent Chromium
MBKSAMHQBjtt^^K^ilJMPwfttiloiMGIMMI (XfI]HtfttDBEM9IUHVC^l£A^^Htt|K£fti9M^Bf
355.3
0.030 (0.33)
2,181.7
0.635
0.247 (0.33)
0.00019 (0.33)
13.4
157.7
0.221 (0.33)
651.8
27.7
157.5
,105.0
0.038 (0.33)
140.7
1.1
0.00017 (0.33)
68.8
0.191 (0.8)
127.2
137.7
123.0
27.8"
73,547.7
10.2
11.1
2,650.1
0.7 (0.8)
3.1
58,891.9
0.0 (0.05)
45
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TABLE 8 (Continued)
SOIL CLEANUP STANDARDS
Cobalt
Copper
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium (carbonate)
Vanadium
Zinc
ttjJBJttBiadagif&jfeiffig^y'-*1^
3,124.7
157.3
221.0
0.0(1,000)
2,264.1
2.3
47.2
314.7
141.8
50.6
6.0
446.8
365.4
Pesticides/Polychlorinated Biphenyls
Aldrin
alpha-Chlordane
Aroclor 1242
Aroclor 1254
Aroclor 1260
4,4'-DDD
4,4'-DDE
4,4'-DDT
Endosulfan I
Endosulfan II
Endosulfan sulfate
Endrin aldehyde
Endrin ketone
gamma-Chlordane
Heptachlor
Heptachlor epoxide
Methoxychlor
0.00147 (0.0017)
0.280
0.002 (0.016)
0.00041 (0.016)
0.005 (0.016)
0.166
0.155
0.040
17.3
15.1
15.7
2.1
21.3
0.00076(0.0017)
0.003
0.00038
25.5
46
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TABLE 8 (Continued)
SOIL CLEANUP STANDARDS
Other
Cyanide (total)
0.165 (2.0)
Notes:
a Number in parentheses is the analytical detection limit. For compounds where the concentration level
corresponding to a risk level of IO'6 is below the detection limit, the detection limit is the cleanup goal.
47
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TABLE 9
OFF-SITE MANAGEMENT APPROACHES FOR CONTAMINATED SOILS
Soils containing a listed
hazardous waste
Treatment by incineration or stabilization with treatment residuals
managed as a hazardous waste
Soils exhibiting a Federal
toxicity characteristic for
organic compounds
Incineration with treatment residuals managed as a hazardous waste
Soils exhibiting a Federal
toxicity characteristic for
organic and inorganic
compounds
Incineration with treatment residuals managed as a hazardous waste
Soils exhibiting a Federal
toxicity characteristic for
inorganic compounds
Stabilization followed by Class I landfill disposal
Non-RCRA hazardous soils
and debris
Appropriately permitted disposal facility
Hazardous debris
Encapsulation followed by Class I landfill disposal
48
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to determine the appropriate off-site management approach before the soils are shipped to an off-site
facility.
Alternative S-l: No Action
Under this alternative, no remedial action would be taken. Rather, Parcel B soil would be left as is,
without implementation of institutional controls, containment, treatment, or removal.
Alternative S-2: Deed Notification; Excavation and Off-Site Disposal
Under this alternative, soil presenting a potential human health risk above the cleanup goals would be
excavated to the ground water table. Section A-l of IR-6 which remained from the removal action will
also be remediated to the groundwater table. Based on data collected during the RI, the total volume of
soil to be excavated is estimated to be 38,000 cubic yards. For areas requiring large excavations,
primarily sites IR-07 and IR-18, stockpile management areas may be established. In these areas, run-on
and runoff controls would be implemented, and collected runoff would be stored on site, sampled, and
discharged to the publicly owned treatment works (POTW) or shipped off site for disposal, as
appropriate depending on the characteristics of the runoff. Because the stockpiles would be within the
area of contamination, land disposal restrictions would not be triggered. Soil that must be managed as a
hazardous waste would be placed in containers if stored outside the area of contamination. The soil
would be shipped off site for disposal; treatment by the landfill operator may be required prior to
disposal if land disposal restrictions are triggered. Clean backfill would be used to restore the excavated
areas. A notification will be placed on the deed indicating that soil below the groundwater table in
remediated areas as specified in the remedial action close-out report may be contaminated. AH future
soils excavated from below the groundwater table in the remediated areas must be managed in
accordance with federal, State and local laws and requirements including local ordinances such as
Articles 4.1 and 20 of the San Francisco Public Works Code. In addition, any owner and/or tenant of
Parcel B who excavates soils containing levels of contaminants in excess of the cleanup goals presented
in Table 8 of this ROD will be restricted from placing the excavated soils onto the ground surface and
restricted from mixing the excavated soils with soils present in the surface to groundwater zone.
49
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Section 2.7 discusses the ARARs for all alternatives. Table 5 identifies which of the requirements in
Section 2.7 are pertinent to Alternative S-2.
The estimated present value of this alternative is $11,161,000. This estimate includes only capital costs;
there are no operation and maintenance (O&M) costs associated with this alternative. The estimated time
to implement this remedy is approximately 12 to 18 months for preconstruction activities and
approximately 3 to 6 months for mobilization, construction, and demobilization.
Alternative S-3: Soil Vapor Extraction of VOC-Containing Soils; Excavation and On-Site
Use as Foundation Cap Material or Off-Site Disposal of Soils Containing
SVOCs and Inorganic Compounds
Under Alternative S-3, except for VOC-containing soil at IR-10, contaminated soil up to 10 feet would be
excavated and disposed of off site, as described under Alternative S-2, or used as sub-base foundation
cap material at the IR-1/21 landfill in Parcel E.
A total of approximately 35,700 cubic yards of soil containing SVOCs, inorganic compounds, or VOCs
combined with SVOCs and/or inorganic compounds would be excavated. If the leachate from the soil
does not exceed NAWQC (adjusted to take into account ambient metals concentrations in groundwater),
the soil would be used as sub-base foundation layer material beneath the cap at the IR-1/21 landfill in
Parcel E, assuming that capping is the selected remedy for that site. The decision whether to cap the
landfill would be evaluated in the Parcel E FS Report. Soil destined for placement at the landfill may be
stored until a final decision on the remedy for the landfill is reached. Because the soil would not contain
hazardous waste, hazardous waste requirements would not apply to the soil storage unit. Soils exceeding
the criteria for use as landfill cap foundation material would be sent off site for disposal; treatment at the
landfill to meet land disposal restrictions may be required.
Based on the RI, approximately 18,000 cubic yards would be managed off site, and approximately 17,500
cubic yards would be used at the IR-1/21 landfill. The excavated areas in Parcel B would be filled with
clean backfill.
50
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Soils containing only VOCs at IR-10 would be treated on site by soil vapor extraction (SVE).
Approximately 900 cubic yards of soil would be treated by SVE using 2 vertical vapor extraction wells.
If predesign sampling indicates a greater area of contamination than currently estimated at IR-10,
additional extraction wells may be installed.
ARARs are discussed in Section 2.7. Table 5 identifies which are the requirements in that section that
are pertinent to Alternative S-3.
The estimated present value of this alternative is $8,554,000. No O&M costs are associated with this
alternative. Approximately 12 to 18 months would be required for design activities before construction.
Approximately 6 to 9 months would be required for construction activities. The length of time the SVE
would operate would depend on soil conditions; preliminarily, it is estimated that approximately 6 to 18
months would be required to meet the cleanup goals.
Alternative S-4: SVE of VOC-Containing Soils; Excavation and Off-Site Disposal or On-Site
Asphalt Encapsulation, Stabilization, and Use of Soils Containing SVOCs,
Inorganic Compounds, or Combined Organic and Inorganic Compounds as
Foundation Cap Material
Alternative S-4 is similar to Alternative S-3 except that on-site asphalt encapsulation and stabilization
would be used to treat, as necessary, certain excavated soils for use as sub-base foundation layer material
for the IR-1/21 landfill cap.
Soil containing only VOCs at IR-10 would be treated on site using SVE as described under Alternative
S-3.
The remaining soil contains SVOCs, inorganic compounds, or combined organic and inorganic
compounds. Approximately 35,700 cubic yards of soil would be excavated. The excavated soil that
exhibits hazardous waste characteristics would be shipped off site. As needed to meet the landfill cap
foundation layer criteria, the remaining soil would be stabilized and encapsulated before placed at the
IR-1/21 landfill. Treated soil that does not meet the criteria for the landfill cap foundation would be
disposed of off site. Under stabilization and encapsulation, the contaminated soil is mixed with reagents
to form a hard, asphalt-like substance that prevents hazardous substances from leaching. During the
51
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design phase, bench-scale tests and treatability studies would be performed to identify the most
appropriate technology process as well as operating conditions and pretreatment requirements.
ARARs are discussed in Section 2.7. Table 5 identifies those requirements that are pertinent to this
remedial alternative.
The estimated present value of this alternative is $9,832,000. No O&M costs are associated with this
alternative. Preconstruction activities, including bench-scale tests and treatability studies, would last
approximately 15 to 21 months. Construction activities, including installation of the SVE system,
excavation, and soil stabilization, would last approximately 7 to 10 months. The length of time the SVE
system would operate depends on the soil conditions, but the preliminary estimate is that it would operate
6 to 18 months to achieve the cleanup goals for soil remaining on Parcel B.
Alternative S-6: Excavation; On-Site Treatment by Thermal Desorption and/or
Solidification/Stabilization as Necessary; and On-Site Use as Foundation
Cap Material at the IR-1/21 Landfill or Off-Site Disposal
Under Alternative S-6, soil containing concentrations of contaminants above the cleanup goals for soil
remaining on site would be excavated up to a depth of 10 feet and, as necessary, treated. The treatment
technology and ultimate disposition of the soil would depend on the type and concentrations of hazardous
substances in the soil.
Soil containing organic compounds only would be treated using thermal desorption. If the treated soil
meets the cleanup goals for soil remaining on site, the soil would be replaced in the excavated areas on
Parcel B. Otherwise, the treated soil would be transported off site for disposal.
Soil containing both organic and inorganic compounds would also be treated by thermal desorption. As
necessary to meet the criteria established for using the soil as sub-base foundation material beneath the
cap at the IR-1/21 landfill (leachate below NAWQC adjusted for ambient metals concentrations), the
treated soil would then be combined with soil containing only inorganic compounds and solidified and
stabilized. Soil that meets the criteria would be used as sub-base foundation cap material. Otherwise, the
soil would be disposed off site. Clean backfill would be placed in the excavated areas. Oil or condensed
52
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organic treatment residuals from the thermal desorption unit would be shipped off site for incineration.
Other solid waste streams, such as cyclone and baghouse residuals, would be blended with contaminated
soil to reduce the moisture content of the feed material and to retreat the fines. The fines would be used
as part of the sub-base foundation material if the concentrations in the material meet the criteria for such
use.
A general discussion of ARARs is provided in Section 2.7. Those requirements that are pertinent to this
alternative are identified in Table 5.
Under this alternative, approximately 12,250 cubic yards of soil would be treated by thermal desorption
and up to 24,750 cubic yards would be solidified and stabilized. A total of approximately 30,000 cubic
yards of soil would be used for the cap foundation layer at the IR-1/21 landfill.
The present value of this alternative is approximately $15,853,000. No O&M costs are associated with
this alternative. Preconstruction activities would last approximately 15 to 21 months and excavation and
construction, treatment system operation, and demobilization would last approximately 9 to 12 months.
Alternative S-8: Capping at IR-07 and IR-18; Excavation and Off-Site Disposal of Soil from
Other Areas
Alternative S-8 involves capping contaminated soil at two locations and, for the other areas, excavation
and off-site disposal of contaminated soil as described under Alternative S-2. This alternative would be
implemented in conjunction with groundwater Alternative GW-5, discussed in Section 2.8.2.
Under the capping component of this alternative, the existing asphalt at IR-07 and IR-18 would be
removed and replaced with a new asphalt cap to prevent exposure to lead in soil. The cap would extend
over approximately 600,000 square feet and cover approximately 32,800 cubic yards of contaminated
soil. Monitoring of the cap would be required to ensure its integrity. In addition, institutional controls
would be implemented to minimize disturbance of the cap. Under this alternative, 3,700 cubic yards
would be treated and/or disposed off site, depending on the soil characteristics.
53
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ARARs are generally discussed in Section 2.7. Table 5 identifies those requirements that are pertinent to
Alternative S-8.
The estimated present value of Alternative S-8 is $3,655,000. Predesign and remedial design activities
would last approximately 12 to 15 months and excavation, capping, and demobilization would last
approximately 6 to 9 months.
2.8.2 Ground water Alternatives
The FS identified two remedial action objectives for groundwater:
Prevention of inhalation of VOCs from A-aquifer groundwater that enters into buildings
Prevention of exposure of aquatic receptors to contaminated groundwater migrating to
San Francisco Bay
The only area in which inhalation of VOCs from groundwater is considered a concern is in the vicinity of
IR-25. Thus, the FS (PRC 1996b) considered alternatives to address this area. The potential threat to
aquatic receptors was evaluated by comparing groundwater concentrations to NAWQC, the Basin Plan
water quality objectives, and ambient metals groundwater concentrations at HPS. Based on this
comparison, sites IR-06, IR-07, IR-10, and IR-25 contain chemical concentrations in groundwater above
these criteria. Based on dilution and attenuation modeling, it was determined that at the
groundwater/surface water interface, the chemical concentrations at IR-06 and IR-10 will drop below
these levels at the tidally influenced zone. For this reason, the FS focused on alternatives to address
IR-07 and IR-25. However, as explained in Section 2.4, IR-25 has now been moved into Parcel C.
Therefore, the following description of alternatives does not include IR-25, even though that area was
originally considered in the FS.
Five groundwater alternatives were initially identified during the FS (PRC 1996b) to address the
remedial action objectives. Based on the preliminary analysis, four alternatives were evaluated in detail
in the FS. Each of these alternatives is described below. More detailed information is provided in
Section 5.2 of the FS report (PRC 1996b).
54
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Alternative GW-1: No Action
Under this alternative, no action would be taken to address groundwater contamination. Rather,
contaminated groundwater would be left as is.
Alternative GW-2: Deed Restrictions; Deed Notification; Lining of Storm Drain System;
Removal of Steam Lines and Fuel Lines; Groundwater Monitoring
Alternative GW-2 consists of several components. First, even though future groundwater use is unlikely,
under this alternative, restrictions would be placed on the deed prohibiting all future uses of groundwater.
Second, potential preferential pathways for direct groundwater discharge to the Bay would be eliminated.
Specifically, sections of the storm drain system that are below the groundwater table would be lined to
prevent groundwater from infiltrating into the system and discharging to the Bay. Sections of the storm
drain system to be lined are located in IR-07 and IR-10. The specific sections of the system to be lined
would be determined during an infiltration study. In those areas requiring lining, the sewer bedding
material would be pressure grouted. Fuel and steam lines would also be removed under this alternative.
Stained soil encountered during the fuel pipeline removal would be excavated and treated as part of the
selected soil alternative or in accordance with the HPS petroleum CAP, depending on the type of
contaminant detected. At IR-07, nickel and copper exceed the water quality criteria in the tidally
influenced zone. Potential sources include spent sandblast grit and bedrock derived fill. The distribution
of nickel in soil samples collected in the area of the nickel groundwater plume is sporadic with only 4 out
of 92 samples exceeding the ambient levels. The distribution of nickel exceedances in groundwater is
equally sporadic and limited. To address this problem, the Navy will remove the soil at IR-07 from the
ground surface to the water table to include nickel contaminated soil that could be leaching to the
groundwater, followed by groundwater monitoring to evaluate the efficiency of the source removal. Post
remediation groundwater monitoring for four quarters will be implemented to evaluate the need for
contingency groundwater actions.
In addition, a notification will be added to the deed indicating that contamination may be present in the
groundwater and in the soils below the groundwater table in the remediated areas as specified in the
remedial action close-out report. All future excavation of soils and groundwater from below the
groundwater table in the remediated areas where contamination may be present must be managed in
55
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accordance with federal, State and local laws and requirements including local ordinances such as
Articles 4.1 and 20 of the San Francisco Public Works Code. In addition, any owner and/or tenant of
Parcel B who excavates soils containing levels of contaminants in excess of the cleanup goals presented
in Table 8 of this ROD will be restricted from placing the excavated soils onto the ground surface and
restricted from mixing the excavated soils with soils present in the surface to groundwater zone. Surface
discharge of contaminated groundwater is prohibited.
Groundwater monitoring for up to 30 years would be implemented to track hazardous substance
migration toward San Francisco Bay, ensure all contaminants posing ecological threats from all possible
Parcel B sites and sources will be tracked and evaluated, and monitor the effectiveness of soil
remediation activities at IR-07 and IR-10. Groundwater at IR-10 shall be monitored to track the potential
degradation of TCE to vinyl chloride. TCE which occurs at lower levels as part of the same contaminant
plume in the adjacent IR-24 site will also be addressed by this groundwater monitoring in IR-10. Should
the levels of vinyl chloride increase, the Navy will activate the groundwater contingency measures.
Since IR-07 is located within the tidally influenced zone, monitoring wells at that site would be placed to
monitor the effectiveness of the soil remedy. Table 10 presents the groundwater monitoring trigger
levels that will be used to evaluate the monitoring well data.
ARARs are generally discussed in Section 2.7. The pertinent ARARs for this alternative are identified
on Table 6 estimated present value of this alternative, including capital and O&M costs, is $3,622,000.
Implementation of this alternative would be expected to take 12 to 18 months.
Alternative GW-3: Deed Restrictions; Lining of Storm Drain System; Removal of Steam Lines
and Fuel Lines; Groundwater Monitoring; Groundwater Extraction,
Pretreatment, and Discharge to POTW from IR-07
In addition to the actions described under Alternative GW-2, GW-3 would involve the extraction of
A-aquifer groundwater from IR-07. The extraction system would consist of seven wells with a combined
pumping rate of 17.5 gallons per minute (gpm). Modeling data indicate that the IR-07 system would
operate for up to 30 years. As necessary, the collected groundwater would first be treated by
equalization. TPH, which separates out in the equalization tank, would be shipped off site for treatment
and disposal. The groundwater would then be treated using air-stripping before it would be discharged to
56
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TABLE 10
GROUNDWATER MONITORING TRIGGER LEVELS - PARCEL B
HUNTERS POINT SHIPYARD - SAN FRANCISCO, CALIFORNIA
National Ambient Water Quality
Criteria Saltwater Aquatic Life
Protection3 (ug/L)
RWQCB Basin Planz
Recommended
Criteria
Additional Toxicity
Information Aquatic
Life
HGAL4
Trigger Levels
Constituent
i
Cadmium
(Hg/L)
9.3
Acute
Chronic
(Mg/L)
5.08
(Mg/L)
1/10"1
Acute
9.3
Chromium (III)
10.300 7
1.030
15.66
1,030
Chromium (VI)
50
50
NA
50
Copper
2.9
2.4
28.04
28.04
Lead
5.6
8.1
14.44
14.44
Manganese
8.140
8,140
Mercury
0.025
0.025
0.60
0.60
Nickel
7.1
8.2
96.48
96.48
Silver
2.3
0.92
7.43
7.43
Thallium
2.130
213
12.97
213
Zinc
Benzene
58
81
5,100
510
75.68
NA
75.68
510
Chloroform
12.000
6,400
NA
6.400
1.2-Dichloroelhane
113.000
11.300
NA
86'
1.2-Dichloroethene
224.000
22.400
NA
85'
2.6-Dinitrololuene
590
59
NA
59
Heptachlor epoxide
0.0036
NA
0.0036
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TABLE 10 (Continued)
GROUNDWATER MONITORING TRIGGER LEVELS PARCEL B
HUNTERS POINT SHIPYARD - SAN FRANCISCO, CALIFORNIA
Constituent '
Hexachloroe thane
Naphthalene
Penlachlorophenol
Phenanthrene
Telrachloroelhylene (PCE)
1 , 1 ,2,2-Tetrachloroethane
1,1,1 -Trichloroelhane
Trichlorocthylene (TCE)
Vinyl chloride
RWQCB Basin Plan 2
(ug/L)
-
-
--
-
-
'
--
--
National Ambient Water Quality
Criteria Saltwater Aquatic Life
Protection 3 (ug/L)
Recommended
Criteria
-
-
7.9
4.6
-
--
--
--
--
Additional Toxicity
Information Aquatic
Life
Acute
940
2,350
--
300
10.200
9,020
31.200
2.000
-
Chronic
--
-.
-
--
450
-
-
--
--
1/10"1
Acute
94
235
--
--
--
902
3.120
200
--
HGAL4
(Mg/L)
NA
NA
NA
NA
NA
NA
NA
NA
Trigger Levels
(ug/L)
94
235
7.9
4.6
145*
147*
117*
II4»
55*
Notes:
NA
Only constituents that (a) have water quality criteria or HGALs and (b) were delected by analysis are presented.
Values represent most stringent water quality objective for surface waters with salinities greater than or equal to 5 parts per thousand, taken from the California Regional Water Quality Control
Board (RWQCB) Basin Plan. Region 2, Table 3-3 (RWQCB I995c)
The national ambient water quality criteria (NAWQC) is the most stringent value of the saltwater aquatic life protection recommended criteria and toxicity criteria (RWQCB I995a).
See Appendix A for information. HGALs do not exist for chromium (VI), cyanide, and organics, because they ore not considered naturally occurring. HGALs apply only to A-aquifer groundwater.
HGAL-adjusted criteria were developed by comparing HGALs with the more stringent value of the (I) NAWQC for protection of saltwater aquatic life and (2) RWQCB Basin Plan, Region 2, water
quality objectives. The HGAL replaced the selected water quality criterion only when the HGAL was greater than the water quality criterion. The values comprise the HG AL-adjusled criteria.
HGAL-adjusted criteria apply only to A-aquifer groundwater.
U.S. EPA. Quality Criteria for Water. 1986. EPA 440/5-86-001
Based on total chromium
Data is not available
Human health-based criteria were developed for VOCs that may represent a human health risk to a future resident at Parcel B. Concentrations of these VOCs in groundwater correspond to an
ELCR of 10"* and were selected as a groundwater RAO for protection of human health based on groundwater to indoor air modeling analysis.
Not applicable. For example, HGALs are not applicable to organics.
58
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TABLE 10 (Continued)
GROUNDWATER MONITORING TRIGGER LEVELS - PARCEL B
HUNTERS POINT SHIPYARD - SAN FRANCISCO, CALIFORNIA
HCAL Hunters Point groundwaler ambient level
NAWQC National Ambient Water Quality Criteria
RWQCB Regional Water Quality Control Board
jjg/L micrograms per liter
59
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the local POTW for treatment and disposal. The ability to discharge to the POTW would depend on
whether the discharge meets POTW concentration and volume limitations. The POTW has indicated that
the potential volume of extracted groundwater, as well as expected concentrations, would be accepted by
the POTW.
A general discussion of ARARs is provided in Section 2.7. The pertinent requirements related to this
alternative are noted on Table 6.
The estimated present value of this alternative is $4,630,000. Implementation of this alternative would
last approximately 15 to 21 months. Groundwater extraction could continue for up to 30 years.
Alternative GW-5: Deed Restrictions; Lining of Storm Drain System; Removal of Steam Lines
and Fuel Lines; Groundwater Monitoring; Slurry Wall Containment and
Cap at IR-07
Under Alternative GW-5, the actions described under Alternative GW-2 would be implemented. In
addition, this alternative includes installation of a 2,000-foot soil-bentonite slurry wall at IR-07 to
prevent migration of hazardous substances to the Bay. The slurry wall would extend approximately 40
feet bgs, to the Bay Mud Deposits or the bedrock. Short-term permeability testing and long-term
compactability testing would be required to develop the appropriate mixture of native soil, ben tonite, and
water for the slurry wall. This alternative would be implemented in conjunction with Soil Alternative
S-8, which proposes an asphalt cap at IR-07.
ARARs are discussed in Section 2.7. Those requirements that are pertinent to this alternative are
identified on Table 6.
The estimated present value of this alternative is $5,275,000. Implementation of this alternative is
expected to last approximately 12 to 18 months for the baseline elements described in Alternative GW-2'
and 6 to 9 months for construction of the slurry wall.
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2.9 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section documents the comparative analysis conducted to evaluate the relative performance of each
alternative in relation to the evaluation criteria. The NCP, 40 CFR Part 300.430(0, identifies nine
criteria that must be considered to evaluate and select a remedy. Overall protection of human health and
the environment and compliance with ARARs are the threshold criteria that must be satisfied for a
remedy to be eligible for selection. Long-term effectiveness and permanence; reduction of toxicity,
mobility, or volume through treatment; short-term effectiveness; implementability; and cost are the
primary balancing criteria used to weigh major trade-offs among the remedies. State and community
acceptance are modifying criteria.
2.9.1 Soil Alternatives
Overall Protection of Human Health and the Environment: All of the alternatives, except Alternative
S-l, no action, would protect human health and the environment by eliminating, reducing, or controlling
site risks through a combination of treatment, engineering controls, or institutional controls. Alternatives
S-2 and S-6 are most effective at eliminating risk because they will result in the removal of soil posing a
potential cancer risk above 1 x 10'6, to the extent practicable given analytical detection limits from Parcel
B. Alternative S-8 relies primarily on on-site containment to reduce risks. Alternatives S-3, S-4, and S-6
incorporate treatment as part of the remedy.
Compliance with ARARs: The State asserts that the Basin Plan and Resolution No. 92-49 are chemical-
specific ARARs for soil. As explained in Section 2.7, the Navy does not agree with the State.
Nevertheless, both the State and the Navy agree that, by remediating soil to a health-based cleanup goal
of 10"6 or less for carcinogens (as practicable given analytical detection limits), an HI of 1 or less for
noncarcinogens (as practicable given analytical detection limits), a lead level of less than 221 mg/kg, or
to ambient levels for certain metals, Alternative S-2 will achieve the objectives in the Basin Plan and
Resolution No. 92-49. The other alternatives, except Alternative S-l, would also satisfy these objectives.
All the alternatives would be implemented to meet their respective action-specific ARARs as set forth on
Table 5. Location-specific ARARs would be met by determining whether the action is consistent with
the coastal zone management plan.
61
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Long-Term Effectiveness and Permanence: Alternative S-l would provide no long-term effectiveness.
Alternatives S-2 and S-6 provide the highest level of long-term effectiveness because all soil would be
excavated, thereby leaving, to the extent possible, no residual risks greater than 10"6 or ambient levels at
Parcel B. Alternatives S-3 and S-4 would provide the next highest level of long-term effectiveness by
excavating soil containing SVOCs, inorganic compounds, and combined organic and inorganic
compounds. Because VOCs would be treated in situ under these alternatives, the magnitude of residual
risks would depend on the effectiveness of the SVE system. The long-term effectiveness of Alternative
S-8 would depend on the effectiveness of the asphalt cap.
Reduction of Toxiciry. Mobility, or Volume Through Treatment: Alternative S-l will not reduce the
toxicity, mobility, or volume of contaminated soil. Alternatives S-3 and S-4 use in situ SVE to reduce
the toxicity and volume of VOCs. Alternative S-6 relies on ex situ thermal desorption to reduce the
toxicity, mobility, and volume of VOCs as well as SVOCs and TPHs. Both Alternatives S-4 and S-6
reduce the mobility of inorganic compounds. Alternatives S-2 and S-8 do not involve, as a principal
element, on-site treatment to reduce the toxicity, mobility, or volume of hazardous substances. However,
if the concentrations in the excavated soil trigger hazardous waste land disposal restrictions, treatment at
the landfill will be required prior to disposal.
Short-Term Effectiveness: Other than Alternative S-l, the alternatives involve significant excavation
activities and therefore may generate dust emissions. The risk to the community is expected to be
minimal from these dust-generating activities. The potential threat to workers is less with Alternatives
S-3 and S-4; less demolition is required because SVE systems would be installed rather than soil
excavated. All the alternatives would include dust- and emission-control measures and appropriate safety
protocols to protect the community and workers during implementation. Impact to the environment
during implementation is minimal under all of the alternatives.
Implementabilitv: All of the alternatives are technically implementable. Equipment for excavation, as
well as the various treatment technologies considered (SVE, thermal desorption, encapsulation and
stabilization), are readily available. In addition, sufficient off-site landfill capacity is available for all the
alternatives involving off-site disposal. Alternatives S-2, S-6, and S-8 may be slightly more difficult to
implement than S-3 and S-4 because they require excavation under existing buildings. Alternatives S-3
through S-8 will require performance testing of the proposed treatment technologies. In terms of
62
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administrative feasibility, Alternative S-2 is easiest to implement. Alternatives S-3, S-4, and S-6 all
depend on the selection of a capping and containment remedy at the IR-1/21 landfill.
Cost: The estimated costs of the alternatives range from approximately $3,655,000 for Alternative S-8 to
$15,853,000 for Alternative S-6. Alternatives S-2, S-3, and S-4 are fairly comparable in cost, ranging
from $8,554,000 to $11,161,000.
State Acceptance: The State concurred that Alternative S-6 may be an appropriate remedy for Parcel B
soil if logistical issues relating to coordinating this alternative with the remedy for the IR-1/21 landfill
could be resolved. The State also supports Alternative S-2, off-site treatment and disposal.
Community Acceptance: During the public comment period, the public expressed concern about any
alternatives (Alternatives S-3, S-4, and S-6) that relied on the use of treated soil as sub-base foundation
material for the IR-1/21 landfill. Instead, the public indicated a preference for off-site treatment and
disposal of contaminated soils.
2.92 Groundwater Alternatives
Overall Protection of Human Health and the Environment: Alternative GW-1 is not protective of human
health and the environment. By imposing deed restrictions, Alternatives GW-2, GW-3, and GW-5 would
prevent human exposure to contaminated groundwater. These alternatives would also protect the
environment by removing preferential pathways for contaminated groundwater to discharge to the Bay;
monitoring would be implemented to track potential migration. Alternatives G-3 and G-5 would provide
additional short-term protection over GW-2 through extraction or containment of groundwater at IR-07.
Alternative GW-2 relies on natural attenuation and dilution rather than extraction.
Compliance with ARARs: As explained in Section 2.7, there is disagreement between the Navy and the
State as to whether certain State plans and resolutions, notably the Basin Plan, Resolution No. 68-16, and
Resolution No. 92-49, are ARARs. The Navy and the State agree that Alternative GW-2, by removing
source areas and monitoring to ensure that hazardous substances at concentrations above ambient levels
for inorganic compounds or NAWQC/Basin Plan water quality objectives (whichever is lower) for
organic compounds, are not entering the Bay, would meet the requirements of Resolution No. 68-16
63
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regardless of whether it is an ARAR. Alternative GW-2 is also consistent with the Basin Plan and
Resolution No. 92-49 in that it promotes the attainment of background water quality by removing source
areas and thus protecting the only possible beneficial use of groundwater, which is freshwater
replenishment. The Basin Plan provides that "[gjroundwaters with a beneficial use of freshwater
replenishment shall not contain concentrations of chemicals which adversely affect the beneficial use of
the receiving surface water." The beneficial uses of the San Francisco Bay include navigation, water
contact and non-contact recreation, ocean commercial and sport fishing, and estuarine habitat. These
beneficial uses will be maintained by removing the source of the contamination (that is, the contaminated
soil). Residual pollution in soils at sites upgradient of the tidally influenced zone will attenuate to
concentrations that will protect this possible beneficial use. Alternatives GW-3 and GW-5 would also
satisfy these requirements. All the alternatives would be implemented to meet their respective
action-specific ARARs as described on Table 6 and the location-specific ARARs described in Section
2.7.
Long-Term Effectiveness: Alternative GW-1 is not effective in the long term because it does not reduce
or eliminate risks from contaminated groundwater. The other alternatives provide long-term protection
through the use of deed restrictions to minimize potential human health risks. Alternatives GW-2, GW-3,
and GW-5 also provide long-term protection to the environment by removing preferential pathways.
Alternatives GW-3 and GW-5 may provide slightly greater long-term effectiveness in that they actively
remove or contain contaminated groundwater; however, the long-term effectiveness of these alternatives
depends on the efficiency of the extraction system and the cap/slurry wall.
Reduction of Toxicitv. Mobility, or Volume Through Treatment: Alternative GW-1 will not reduce the
toxicity, mobility, or volume of hazardous substances. Alternatives GW-3 and GW-5 reduce the volume,
toxicity, and mobility of contaminated groundwater by extraction and treatment.
Short-Term Effectiveness: Because no action is taken under Alternative GW-1, it would pose no
short-term risks to workers, the community, or the environment. Of the other three alternatives,
Alternative GW-2 provides the greatest short-term effectiveness. Under all the alternatives, the potential
risks to the community and workers are minimal and related largely to possible fugitive dust emissions.
Alternatives GW-3 and GW-5 create greater risks to the community than Alternative GW-2 as a result of
the greater volume of soil that would be disturbed. Potential risks to workers are minimal and would be
64
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controlled through the use of appropriate safety protocols. Alternative GW-5 presents the greatest risk to
workers because of the heavy construction required to install the slurry wall. Under GW-2, GW-3, and
GW-5, short-term risks to the environment are minimal.
Implementability: Alternative GW-2 is technically and administratively implementable. Alternatives
GW-3 and GW-5 would be more difficult to implement than Alternative GW-2. GW-3 and GW-5 both
require placing an extraction system and obtaining a permit from the POTW to discharge contaminated
groundwater. Because of potential difficulties associated with the construction of a slurry wall, GW-5
would be the most difficult alternative to implement.
Cost: Alternative GW-1, no action, involves no costs. The estimated capital and O&M costs for the
other three alternatives is as follows: $3,622,000 for Alternative GW-2; $4,630,000 for Alternative
GW-3, and $5,275,000 for Alternative GW-5.
State Acceptance: No action is unacceptable to the State. The State supports the selection of
Alternative GW-2.
Community Acceptance: The community raised no objections to implementation of Alternative GW-2.
2.10 SELECTED REMEDY
Based on consideration of the requirements of CERCLA, the detailed analysis of alternatives, and public
comments, the Navy, with the concurrence of EPA and the State of California, has determined that
Alternative S-2 (Deed Notification, Excavation and Off-Site Disposal) and Alternative GW-2 (Deed
Restrictions, Deed Notification, Storm Drain System Lining, Fuel Line and Steam Line Removal, and
Groundwater Monitoring) are the most appropriate remedies for soil and groundwater, respectively, for
Parcel B at HPS in San Francisco, California. The proposed schedule for implementing the remedy is set
forth in Table 11.
65
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TABLE 11
PROPOSED REMEDIAL DESIGN/REMEDIAL ACTION SCHEDULE
Task . ... ../,,;.
Draft remedial design and remedial action
(design drawings and performance
specifications) work plans
Final remedial design and remedial action work
plans
Implementation of remedial action
Completion of construction for remedial action
EstimatedJDate*
August 14, 1997
(date submitted)
February 14, 1998
June 15, 1998
June 15, 1999
This schedule is estimated based on current information and is subject to modification based on
changed conditions during RD/RA.
The goal of the soil response action is to control risks posed by the ingestion of or dermal contact with
contaminated soils or inhalation of vapors and fugitive dusts containing hazardous substances. The
proposed cleanup goals for soil remaining on Parcel B are based on reducing risks to future residents to
an ELCR of 10"6 and an HI of 1 or, for certain metals, to ambient concentrations. However, in some
instances, these concentrations are below analytical detection limits and therefore, for those substances,
the cleanup goal is the detection limit. The chemical-specific cleanup goals are listed in Table 8.
Approximately 38,000 cubic yards of soil will be excavated from areas throughout Parcel B (Figure 5).
Section A-l of IR-6 remaining from the removal action will also be remediated to groundwater.
Excavated soil will be stockpiled within the area of contamination without triggering land disposal
restrictions. Controls will be instituted to eliminate surface run-on and runoff while the soil is stockpiled.
The excavated soil will be sampled and characterized. Soil that contains listed hazardous waste or that
exhibits hazardous waste characteristics will be placed in containers for shipment off site; soil that does
not require management as a hazardous waste may be'moved to a central stockpile location on HPS prior
to shipment off site. The soil will be shipped off site either by rail cars or by trucks. A notification will
be placed on the deed indicating that soil below the groundwater table in the remediated areas as
specified in the remedial action close-out report may be contaminated. All future soils excavated from
66
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SAN FRANCISCO BAY
LEGEND
/V * site IOWOA/ICS
V »80 ?^ .*?* £?*
I -...;] SOt CICAVitOw ARCAS
' (iico»Po«Aiioi< UPtiueo 3». I»«T)
CNCIHUMNO rCLO ACIIVtTT WEST
. _ Ml VA- mf flM|
«^VI H" *^**4 IW f«MDHa .M»UMk
ricuRC s
PAHCO.
KM. (XCAVATWN AUAS
-------
below the groundwater table in remediated areas must be managed as potential hazardous waste. In
addition, any owner and/or tenant of Parcel B who excavates soils containing levels of contaminants in
excess of the cleanup goals presented in Table 8 of this ROD will be restricted from placing the
excavated soils onto the ground surface and restricted from mixing the excavated soils with soils present
in the surface to groundwater zone. The ARARs for this action are listed on Table 5. Alternative S-2
was selected over the other alternatives because it provides the best balance of the nine NCR criteria. It
will provide overall protection to human health and the environment by reducing the residual soil risks on
Parcel B to below an ELCR of 10"6 and an HI of 1.0, or to ambient concentrations. Alternative S-2 is
widely supported by the community, is more cost-effective than most of the other alternatives, and is
easily implemented within a short time frame.
For groundwater, the objective of the response action is to prevent groundwater containing hazardous
substances from migrating to the Bay at concentrations that may pose a threat to aquatic receptors.
Alternative GW-2 (Deed Restrictions, Deed Notification, Storm Drain System Lining, Fuel Line and
Steam Line Removal, and Groundwater Monitoring) achieves this objective by removing preferential
groundwater pathways, such as the sewer lines, soil source removal at IR-07, where soil will be removed
to the groundwater table, and monitoring, and deed notification indicating that contamination may be
present in the groundwater in the remediated areas as specified in the remedial action close-out report.
All resurfaced groundwater will be managed in accordance with federal. State and local laws and
requirements including local ordinances such as Articles 4.1 and 20 of the San Francisco Public Works
Code. Surface discharge of contaminated groundwater is prohibited. Groundwater at IR-10 shall be
monitored to track the potential degradation of TCE to vinyl chloride. Should the levels of vinyl chloride
increase, the Navy will activate the groundwater contingency measures. The ARARs for this action are
identified on Table 6.
The Navy shall monitor the groundwater to ensure that the NAWQC and the ambient concentrations for
metals are not exceeded at the high tide line of the Parcel B tidally-influenced zone which is the point of
compliance. Groundwater sentinel monitoring wells will be located to ensure contaminants posing
potential ecological threats from all possible Parcel B sites and sources will be tracked and evaluated, and
to monitor any migration at the parcel boundary along IR-07 and IR-18. Data from the B-aquifer will be
collected to assist in developing the monitoring program. A groundwater monitoring plan that uses a 5-
68
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year buffer zone upgradient of the tidally influence zone will be instituted. A series of sentinel wells will
be located upgradient from the point of compliance a distance equivalent to a groundwater travel time of 5
years. A schematic of the groundwater monitoring plan is shown in Figure 6. The sentinel well
monitoring locations and monitoring program will be presented in the Parcel B Groundwater Contingency
Plan that will be prepared during the remedial design. The Navy shall monitor the groundwater to ensure
that 10 times NAWQC or Basin Plan criteria (whichever is higher) for organic compounds and ambient
groundwater concentrations of metals are not exceeded at the sentinel wells. The groundwater monitoring
trigger levels presented in Table 10 will be used for the monitoring well results. As default criteria, the
Navy will undertake the following actions if groundwater monitoring data exceed the above criteria:
Orally notify the regulatory agencies within 15 days of any exceedance of the
groundwater monitoring criteria
Consult with the regulatory agencies regarding the exceedance
Conduct monitoring to verify the exceedance in accordance with the monitoring plan
(which will be developed during the remedial design/remedial action phase)
At the written request of one or more of the regulatory agencies, the Navy will develop a
proposal as to what should be done to address the exceedance, which may result in a
change in the remedy
The change may require a ROD amendment depending on the significance of the change.
Any changes to the remedy will be addressed and presented to the public in accordance
with CERCLA
After the RD, the Federal Facilities Agreement (FFA) shall continue to apply through
operation and maintenance of the Parcel B response action.
During the RD phase, the Navy will develop the groundwater monitoring program parameters. Although
groundwater monitoring may be conducted for up to 30 years, the monitoring plan, including the analyses
conducted, the sampling frequency, and the overall length of the monitoring program, will be re-
evaluated after 5 years of monitoring. In addition, during RD, the Navy will develop a groundwater
model to calculate a site-specific multiplier to be applied to the NAWQC/Basin Plan water quality
objectives and ambient metal concentration to reflect the expected dilution attenuation that is likely to
occur as contamination migrates from the monitoring well to the Bay. Once these site-specific criteria
69
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FRANCISCO PA}'
IR-26
Mfttm »-0> M
MNT Or OOMUMCt KMKXM «CU
.
le iv«i»n imcmiKIt or
cui ertcctoj
l COWf»l»nxt CICCUM
m » PMCCL
r_~i~j
ENGINEERING FIELD ACTIVITY WEST
»» **«>. t*ri**>
IP.I 6
CROONDWATER MONITORING
PLAN SCHEMATIC
PARCEL B RECORD or occisir
-------
are developed, they will replace the 10 times default criteria as the trigger for taking any ground water
action.
While part of the groundwater monitoring plan is to deploy a series of sentinel wells with 5-year buffer
zone to provide an early warning system, the Navy and the regulatory agencies recognize there are
contaminants (specifically, nickel) in the vicinity of IR-7 that have already exceeded cleanup criteria in
the buffer zone. It is agreed that groundwater in the area will be closely monitored while the source
removal (soil excavation in the contaminated area) is implemented. If monitoring data indicates the
source removal does not effectively reduce the contamination in groundwater, the groundwater
contingency plan will take effect.
To minimize any potential migration off site onto IR-07 and IR-18, the sheet piling installed to shore the
area for excavation will remain in place after the excavation is completed. A restriction shall be placed
on the Parcel B deed requiring the following:
Prohibiting all use and consumption of Parcel B groundwater in the shallow water
bearing zone(s) to 90 feet below ground surface;
prohibiting surface discharge of contaminated groundwater;
notifying all future owners of Parcel B that contamination may be present in the
groundwater and in the soils below the groundwater table in the remediated areas as
specified in the remedial action close-out report;
notifying all future owners that the Parcel B storm drains are lined;
requiring all future owners to indicate, in writing, to all tenants on Parcel B that
contamination may be present in the groundwater and in the soils below the groundwater
table in the remediated areas as specified in the remedial action close-out report, and that
the storm drains are lined;
requiring all future owners and tenants of Parcel B, which excavate soils and surface
groundwater from below the groundwater table in remediated areas as specified in the
remedial action close-out report, that contamination may be present and must be
managed in accordance with federal, State and local laws and requirements including
local ordinances such as Articles 4.1 and 20 of the San Francisco Public Works Code;
and
71
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' requiring any owner and/or tenant of Parcel B who excavates soils containing levels of
contaminants in excess of the cleanup goals presented in Table 8 of this ROD will be
restricted from placing the excavated soils onto the ground surface and restricted from
mixing the excavated soils with soils present in the surface to groundwater zone.
An appendix to the Parcel B Remedial Design, a primary deliverable under the FFA, shall detail how the
institutional controls outlined above shall be implemented and enforced.
2.11 STATUTORY DETERMINATIONS
As required under Section 121 of CERCLA, the selected remedial action is protective of human health
and the environment, complies with federal and state requirements that are legally applicable or relevant
and appropriate, and is cost effective. The selected remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable for this site. However, it does not satisfy the
statutory preference for remedies that employ treatment to reduce toxicity, mobility, and volume as a
principal element. This is due to numerous comments received during the public comment period
voicing strong opposition to on-site treatment and disposal, the alternative initially proposed by the Navy
for the Parcel B contaminated soils. In response to community concerns, the Navy has selected
excavation and off-site disposal for the Parcel B contaminated soils. Furthermore, because this remedy
will result in hazardous substances remaining on site above health-based levels, the Navy shall conduct a
review pursuant to CERCLA Section 121,42 USC Section 9621, at least once every five years after
commencement of remedial action to ensure that the remedy continues to provide adequate protection to
human health and the environment. For groundwater, deed restrictions will limit human exposure to
groundwater. Removal of preferential pathways and soil excavation combined with groundwater
monitoring will provide environmental protection.
2.12 DOCUMENTATION OF SIGNIFICANT CHANGES
The proposed plan for Parcel B was released for public comment in October 1996. The Navy, EPA, and
the State of California reviewed all written and oral public comments submitted during the public
comment period on the proposed plan. Upon review of these comments, the Navy has selected a
different alternative for soil. The preferred groundwater alternative has also been modified as a result of
re-defining the Parcel B and Parcel C boundary and incorporating IR-25 into Parcel C.
72
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The preferred soil alternative identified in the proposed plan was Alternative S-6 (Excavation, Treatment
by Thermal Desorption and/or Solidification/Stabilization as Necessary, and Use as Cap Foundation
Material at the IR-1/21 Landfill or Off-Site Disposal). Implementation of Alternative S-6 was contingent
on selection of a capping and containment remedy at the IR-1/21 landfill in Parcel E. In the proposed
plan, the Navy proposed Alternative S-2 (Excavation and Off-Site Disposal) as an alternative remedy in
the event that capping and containment at IR-1/21 was not selected or the treated soils could not be used
as sub-base foundation material. During the public comment period, significant concerns were voiced by
community members concerning the relationship of the remedy for Parcel B to the remedy for the IR-
1/21 landfill at Parcel E. In addition, new information became available on the relative costs to dispose
of contaminated soils off site. For these reasons, the Navy has chosen, in this ROD, to select Alternative
S-2 as the final soil remedy for Parcel B.
At IR-10, in light of concerns about the potential degradation of TCE and the potential of the degraded
compounds to offgas into the soil and into buildings, the Navy has decided to implement a safety plan to
address this concern. This concern will be addressed in the groundwater monitoring plan, and it will
include groundwater sampling at IR-10 for TCE and its degradation compounds.
In addition, because of concerns regarding DNAPLs at IR-25, the Navy has decided to evaluate and
consider additional remedial alternatives for IR-2S. Consequently, remedial alternatives to address the
contamination at IR-25 will be considered in the Parcel C FS and a remedy selected as part of the Parcel
C ROD. Thus, the groundwater remedy as originally proposed has been modified only in that those
components of the remedy designed to address conditions at IR-25 have not been selected under this
ROD.
73
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REFERENCES
California Environmental Protection Agency Department of Toxic Substances Control (DTSC). 1992.
"Supplemental Guidance for Human Health Multimedia Risk Assessments of Hazardous Waste
Sites and Permitted Facilities." Office of Science Advisor. July.
DTSC. 1994. The Blood Lead Computer Model.
IT Corporation (IT). 1997. "Draft Project Completion Report. Exploratory Excavations, Hunters Point
Naval Shipyard. San Francisco, California." September 29.
PRC Environmental Management, Inc. (PRC). 1996a. "Hunters Point Shipyard, Parcel B, Draft Final
Remedial Investigation Report." June 3.
PRC. 1996b. "Hunters Point Shipyard, Parcel B. Draft Final Feasibility Study Report." Septembers.
Regional Water Quality Control Board, San Francisco Bay Region. 1996. "San Francisco and Northern
San Mateo County Pilot Beneficial Use Designation Project. Part 1: Draft Staff Report."
April 4.
U.S. Environmental Protection Agency (EPA). 1989. "Risk Assessment Guidance for Superfund,
Volume I: Human Health Evaluation Manual (Part A), Interim Final." Office of Emergency and
Remedial Response. Washington, D.C. EPA/546/1-29/002. December.
EPA. 1995. "Region IX Preliminary Remediation Goals (PRGs) - Second Half 1995." September 1.
74
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APPENDIX A
SUMMARY OF HAZARDOUS SUBSTANCES EXCEEDING SCREENING CRITERIA
-------
SUMMARY OF HAZARDOUS SUBSTANCES EXCEEDING SCREENING CRITERIA
Site
1R-06
Impacted
Medium
Soil
Groundwater
Hazardous Substance Exceeding
Screening Criteria*
Arsenic
Beryllium
Chromium
Lead
Manganese
Nickel
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene
Aldrin
Aroclor-1260
TPH-d
Cadmium
Copper
Manganese
Nickel
1.2-DCA
1,2-DCE (total)
Benzene
Chloroform
cis-U-DCE
Methylene chloride
Vinyl chloride
1 ,4-DicKlorobenzene
Bis(2-ethylhexyl) phthalate
Carbazole
Naphthalene
Pentachlorophenol
Phenanthrene
TPH-d
TPH-mo
TPH-extractables (unknown
hydrocarbons)
TOG
Concentration Range
0.31 -56.6mg/kg
0.18-0.91 mg/kg
40.0- 1,9 10 mg/kg
0.67 - 2,580 mg/kg
169 -4,640 mg/kg
2 1.7 -3,390 mg/kg
87 -830 ug/kg
91 - 1,300 ug/kg
41 -2400 Mg/kg
95 - 2,500 ug/kg
60 - 84 ug/kg
12- 130 Mg/kg
77- 150,000 ug/kg
9 - 26,000 mg/kg
3.0 - 6.4 ug/L
1.6 -58.2 ug/L
26.8- 8,860 ug/L
13.6 -117 ug/L
5 - 1 ug/L"
5- 130 ug/L
5 -72 Ug/L
4 - 24 ug/L
3 -340 ug/L
5 - 17 Ug/L
5 - 62 Ug/L
10-5ug/Lb
10 -20 ug/L
20 - 53 ug/L
28- 1,700 ug/L
50 - 3 ug/Lb
17- 160 ug/L
430- 1 1,000 ug/L
170 -3,100 ug/L
630 - 7,300 ug/L
800 - 6,000 ug/L
A-l
-------
SUMMARY OF HAZARDOUS SUBSTANCES EXCEEDING SCREENING CRITERIA
(Continued)
Site
IR-06
IR-07
IR-10
Impacted
Medium
Groundwater
(Continued)
Soil
Groundwater
Soil
Groundwater
Hazardous Substance Exceeding
Screening Criteria*
TRPH
Arsenic
Beryllium
Copper
Lead
Manganese
Nickel
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenzo(a,h)anlhracene
Aroclor-1260
TPH-d
TOG
Antimony
Barium
Cadmium
Chromium
Copper
Nickel
Thallium
PCA
Benzene
PCE
Lead
Nickel
TCE
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene
Antimony
Beryllium
Chromium
Concentration Range
1,000- 800 ng/Lb
0.56 - 929 mg/kg
0.05- 1.7 mg/kg
2.7 - 2,540 mg/kg
0.72 -5, 120 mg/kg
47.6 - 8,490 mg/kg
24.6 - 3,550 mg/kg
37- 1,500 ug/kg
41 -980 ug/kg
37-1, 100 ug/kg
37 - 91 ug/kg
62 - 340 ug/kg
12 -4,200 mg/kg
33 - 27,000 mg/kg
29.7-44.1 ug/L
22.4- 1,320 ug/L
2.7 -5. 6 ug/L
3.8- 1,260 ug/L
2.0 - 40.6 ug/L
14.9- 7,120 ug/L
2.7-28.1 ug/L
5 - 1 ug/Lb
5 - 2 ug/Lb
5 - 2 ug/Lb
1.2 -777 mg/kg
6.1 -2,440 mg/kg
1- 980,000 ug/kg
48- 1,100 ug/kg
39- 1,300 ug/kg
54-1, 400 ug/kg
38- 1,400 ug/kg
75 - 75 ug/kg
10.1 -46.6 ug/L
0.41 - 1.4 ug/L
1.6- 1,140 ug/L
A-2
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SUMMARY OF HAZARDOUS SUBSTANCES EXCEEDING SCREENING CRITERIA
(Continued)
Site
IR-10
IR-18
IR-20
Impacted
Medium
Groundwater
(Continued)
Soil
Groundwater
Soil
Hazardous Substance Exceeding
Screening Criteria*
Chromium VI
Copper
Silver
1,2-DCE
Chloroform
cis- 1,2-DCE
TCE
Vinyl chloride
Bis(2-ethylhexyl)-phthalate
2,6-Dinitroioluene
TPH-d
TPH-mo
Arsenic
Beryllium
Chromium
Lead
Manganese
Nickel
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Dibenzo(a,h)anthracene
Indeno( 1 ,2,3-cd)pyrene
Aroclor-1260
Aroclor-1254
TPH-d
TPH-mo
TRPH
Silver
Thallium
TPH-mo
Arsenic
Beryllium
Concentration Range
50.0- 1,680 ug/L
1.8 -39.5 ug/L
6.9 - 20.7 ug/L
3 - 66 ug/L
2 - 0.8 ug/Lk
1 - 15 ug/L
2 - 45ug/L
4-3ug/Lb
18- 120 ug/L
25 - 58 ug/L
100- 160ng/L
100 -820 Ug/L
0.85- 11.4mg/kg
0.04 - 0.92 mg/kg
14.1 -2,1 10 mg/kg
0.93 - 2,380 mg/kg
93.7 - 2,370 mg/kg
19.1 -3,670 mg/kg
13- 10,000 fig/kg
34 - 8,600 ug/kg
33 - 8,700 ug/kg
33 - 5,600 ug/kg
17 - 12.000 ug/kg
95-1, 200 ug/kg
51- 4,000 ug/kg
31- 3,400 ug/kg
45-1 2,000 ug/kg
11- 1,100 mg/kg
7 - 25,000 mg/kg
3- 14,000 mg/kg
8.8 - 8.8 ug/L
2.8 - 30.7 ug/L
100- 740 ug/L
0.82 -11. 2 mg/kg
0.17- 1.3 mg/kg
A-3
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SUMMARY OF HAZARDOUS SUBSTANCES EXCEEDING SCREENING CRITERIA
(Continued)
Site
IR-20
IR-23
Impacted
Medium
Soil (Continued)
Groundwater
Soil
Hazardous Substance Exceeding
Screening Criteria*
Chromium III
Chromium VI
Lead
Manganese
Nickel
Benzo(a)pyrene
Aroclor-1260
TPH-g
TPH-d
Barium
Lead
Mercury
Nickel
Thallium
Zinc
Benzene
TPH-g
TPH-d
TPH-mo
TOG
Arsenic
Beryllium
Chromium
Lead
Manganese
Nickel
Vanadium
Benzo(a)anlhracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Dibenzo(a,h)anthracene
Indeno( 1 ,2,3-cd)pyrene
4.4N-DDT
Aroclor-1260
Concentration Range
11.2-2,990mg/kg
0.11 - 1.1 mg/kg
2.1-578mg/kg
143- 14.100 mg/kg
3.0 - 5,580 mg/kg
140- 140 fig/kg
21 - 3,100 Mg/kg
2 - 590 mg/kg
12 -3,400 mg/kg
66.0- l,020ng/L
1.4- 67.2 u.g/1
0.17- 2.0 Mg/1
27.9- 122 Mg/1
1.8- 16.5 Mg/L
18.2- 2,580 ng/1
10- 10 Mg/L
50- 190 Mg/L
100-150ng/L
100 -560 Mg/L
5,000 - 3,800 Mg/Lb
0.86 - 22.8 mg/kg
0.05 - 3.2 mg/kg
19.9 -1,330 mg/kg
0.33 -1,080 mg/kg
292- 2,350 mg/kg
54.9 - 2,050 mg/kg
6.5-1. 960 mg/kg
48 -14,000 Mg/kg
38 -2 1,000 Mg/kg
100- 16,000 Mg/kg
54 -11, 000 Mg/kg
81 - 14,000 ng/kg
930 - 930 Mg/kg
53- 12,000 Mg/kg
11 -2,800 jig/kg
67 - 560 Mg/kg
A-4
-------
SUMMARY OF HAZARDOUS SUBSTANCES EXCEEDING SCREENING CRITERIA
(Continued)
Site
IR-23
IR-24
IR-26
Impacted
Medium
Soil (Continued)
Groundwaier
Soil
Groundwater
Soil
Hazardous Substance Exceeding
Screening Criteria*
TPH-mo
TRPH
Bis(2-ethylhexyl) phthalate
TPH-mo
TRPH
Arsenic
Lead
Manganese
Nickel
TCE
Chrysene
Aroclor-1260
TPH-g
TPH-d
TRPH
Cadmium
Copper
Lead
Carbon Disulfide
TPH-g
TPH-purgeable unknown hydrocarbons
TPH-d
TPH-mo
TRPH
TOG
TRPH
Arsenic
Beryllium
Chromium
Lead
Manganese
Mercury
Nickel
TCE
Benzo(a)anthracene
Benzo(a)pyrene
Concentration Range
6 - 2,600 mg/kg
4-3,100mg/kg
4-31 ug/L
100- 1,100 ug/L
1,000- 800 ug/Lb
0.51 - 12.1 mg/kg
0.42- 165 mg/kg
126 -7,320 mg/kg
12.9- 2,3 10 mg/kg
3 - 6,300 ug/kg
290 - 7,800 ng/kg
45-1, 400 ug/kg
1 - 920 mg/kg
24- 13,000 mg/kg
16 -5,300 mg/kg
1.6- 13.5 ug/1
28.7 - 28.7 ug/1
11.0- 15.2 ug/L
30 - 66 ug/L
310 -800 Ug/L
1,000 -2,800,000 ug/L
1,000 -66,000 ug/L
810 -8,700 ug/L
1,300- 4,900 ug/L
5,000 - 9,500 ug/L
5,000 -63,000,000 ug/L
0.36 -91 5 mg/kg
0.02- 1.0 mg/kg
19.1 - 1,430 mg/kg
0.80 - 3,340 mg/kg
106- 11,200 mg/kg
0.05 -316 mg/kg
19. 1-2,940 mg/kg
3 -21, 000 Mg/kg
54 - 7,000 ug/kg
64 - 6,800 ug/kg
A-5
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SUMMARY OF HAZARDOUS SUBSTANCES EXCEEDING SCREENING CRITERIA
(Continued)
Site
IR-26
SI-31
IR-42
SI-45
IR-46
Impacted
Medium
Soil (Continued)
Groundwater
Hazardous Substance Exceeding
Screening Criteria*
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Dibenzo(a,h)anthracene
Indeno( 1 ,2,3-cd)pyrene
Aroclor-1260
TPH-mo
TRPH
Cadmium
Nickel
Zinc
2,4,6- trichlorophenol
heptachlor epoxide
TPH-d
TPH-mo
TRPH
No contaminated media
Soil
Steam line
system water
Soil
Barium
Chromium
Lead
Manganese
Nickel
1,1-DCE
Benzene
Trichloroethene
Xylenes
Antimony
Arsenic
Beryllium
Chromium
Lead
Manganese
Nickel
Benzo(a)pyrene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene
Concentration Range
60- 7,000 ug/kg
31 -5,700 ug/kg
63-8,100ng/kg
32- 1,700 ug/kg
47 -3,800 ug/kg
10- 1,500 ug/kg
6-9,100mg/kg
3 - 26,000 mg/kg
0.20 - 6.2 ug/L
18.0- 116 Ug/L
1.9- 145 ug/L
10 -24 ug/L
0.01- 0.013 ug/L
100 -320 ug/L
100- 790 Mg/L
900- 1.000ug/Lb
60.4 - 476 mg/kg
83.9 - 540 mg/kg
4.0- 139 mg/kg
176 -2,640 mg/kg
56.8 - 765 mg/kg
7-7ug/L
41-41 ug/L
9-9ug/L
260 - 260 ug/L
0.76 -6 1.2 mg/kg
0.49- 13.9 mg/kg
0.04 - 0.84 mg/kg
9.4- 1,480 mg/kg
0.81- 251 mg/kg
43.1 -13.700 mg/kg
8.5 - 6,480 mg/kg
36- 1.200 Mg/kg
23 -810 ug/kg
26 - 330 Mg/kg
A-6
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SUMMARY OF HAZARDOUS SUBSTANCES EXCEEDING SCREENING CRITERIA
(Continued)
Site
IR-46
IR-50
IR-50
Impacted
Medium
Soils (Continued)
Groundwater
Storm drain
system
sediment
Test-pit soil
near storm
drain system
Hazardous Substance Exceeding
Screening Criteria"
Benzo(a)anthracene
Benzo(b)fluoranthene
Indeno( 1 ,2,3-cd)pyrene
Aroclor-1260
TPH-d
TPH-mo
TRPH
TPH-g
TPH-Not determined purgeable
hydrocarbon
Cadmium
Thallium
Bis(2-ethylhexyl)-phthalate
2,6-Dinitrotoluene
TPH-g
TPH-d
TPH-mo
TRPH
Antimony
Arsenic
Cadmium
Chromium
Lead
Nickel
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Chrysene
Aroclor-1242
Aroclor-1260
TPH-d
TRPH
Chromium
Manganese
Benzo(a) pyrene
TPH-d
Concentration Range
24- l,500jig/kg
32-1 ,300 Mg/kg
61 -900 Mg/kg
17- 26,000 Mg/kg
6 - 6,500 mg/kg
6 - 9,700 mg/kg
3- 18,000 mg/kg
0.6 - 2,200 mg/kg
57- 1,500 mg/kg
0.36 - 16.5 Mg/L
2.8- 13.6 Mg/L
8 - 34 Mg/L
25- 100 Mg/L
50 -220 Mg/L
150- 14.000 Mg/L
130- 1,300 Mg/L
1,500- 10,000 Mg/L
5. 1-258 mg/kg
3.9 - 20.6 mg/kg
0.54 - 20.9 mg/kg
66.6 - 444 mg/kg
195 -3,190 mg/kg
46.3 -41 2 mg/kg
84-1 2,000 Mg/kg
220 - 5,600 Ml/kg
320 - 320 fig/kg
210 -21,000 Mg/kg
300 -300 Mg/kg
150 - 39,000 Mg/kg
180 -2,300 mg/kg
86 - 6,000 mg/kg
277 - 694 mg/kg
1,240 -3,360 mg/kg
120 -120 Mg/kg
3, 100 -3. 100 mg/kg
A-7
-------
SUMMARY OF HAZARDOUS SUBSTANCES EXCEEDING SCREENING CRITERIA
(Continued)
Site
IR-50
IR-51
IR-60
IR-61
IR-62
Impacted
Medium
Groundwater
near sanitary
sewer system
Soil
Soil
Groundwater
Soil
Groundwater
Soil
Groundwater
Hazardous Substance Exceeding
Screening Criteria*
Mercury
TPH-mo
Aroclor-1260
Arsenic
Beryllium
Lead
Manganese
Benzo(a)pyrene
Benzo(b)fluoranthene
TPH-mo
TRPH
Cadmium
TPH-mo
Arsenic
Aroclor-1260
TRPH
TPH-mo
Chromium
Nickel
TPH-g
TPH-d
TRPH
Hexachloroethane
TPH-g
TPH-d
TPH-mo
TRPH
Concentration Range
0.14-0.91 ug/L
\QO-250\igfL
35-1 5,000 ug/kg
0.74-21.1mg/kg
0.02 - 0.73 mg/kg
3.6 - 859 mg/kg
157 -2,880 mg/kg
180 -620 ug/kg
27 - 650 jig/kg
6- 1,400 mg/kg
12 -4,300 mg/kg
0.36-31.7jig/L
100-320ng/L
0.82 - 15.6 mg/kg
1 10 - 250 Mg/kg
12 -2,300 mg/kg
100-210fig/L
57.3 -1,480 mg/kg
86.2 - 2,530 mg/kg
89 -5, 100 mg/kg
8 - 9,700 mg/kg
3- 13,000 mg/kg
5- 10u,g/L
750- 8,700 jig/L
340 - 35,000 ug/L
180- 1,300 Mg/L
1,1 00- 23,000 ng/L
Nole:
a
The hazardous substances listed exceed EPA Region IX residential preliminary remediation goals (PRO or ambient levels for soil; or
EPA Region IX residential PRGs or National Ambient Water Quality Criteria and groundwater ambient levels.
Value detected is based on single detection. The first value is the detection limit and the second value is the concentration detected.
A-8
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APPENDIX B
RESPONSIVENESS SUMMARY FOR PARCEL B PROPOSED PLAN
HUNTERS POINT SHIPYARD, SAN FRANCISCO, CALIFORNIA
-------
CONTENTS
Section Page
1.0 OVERVIEW 1
2.0 BACKGROUND ON COMMUNITY INVOLVEMENT 2
3.1 COMMENTS AND QUESTIONS FROM PUBLIC MEETING ON PARCEL B
PROPOSED PLAN, NOVEMBER 13, 1996 3
3.1.1 IR-1/21 Landfill in Parcel E 4
3.1.2 Hazards Associated with Fishing 5
3.1.3 Contracting Procedures 6
3.1.4 Transport of Wastes Off-Site 6
3.1.5 Noise 7
3.1.6 Public Comment and the Decision-Making Process on the
Proposed Plan for Parcel B 7
3.1.8 Potential Health Effects 9
3.1.9 Miscellaneous Questions 10
3.2 COMMENTS FROM CITY AND COUNTY OF SAN FRANCISCO,
DEPARTMENT OF PUBLIC HEALTH, BUREAU OF ENVIRONMENTAL
HEALTH MANAGEMENT 11
3.3 COMMENTS FROM THE COALITION FOR BETTER WASTEWATER
SOLUTIONS 12
3.4 COMMENTS FROM THE INNES AVENUE COALITION 15
3.6 COMMENTS FROM LESLIE KATZ, BOARD OF SUPERVISORS, CITY AND
COUNTY OF SAN FRANCISCO 21
3.7 COMMENTS FROM ECDC ENVIRONMENTAL 21
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1.0 OVERVIEW
In October 1996, the Navy's "Draft Final Proposed Plan For Hunters Point Shipyard Parcel B" was
prepared and presented to the public to describe the proposed cleanup alternatives for Parcel B, located
within Hunters Point Shipyard (HPS), San Francisco, California. The Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) requires that a responsiveness summary detailing
community comments on the Navy's proposed cleanup alternative as presented in the proposed plan and
the Navy's response to those comments be prepared following the public comment period. This
document has been prepared to fulfill that requirement.
The proposed plan presented six cleanup options for soil and four cleanup options for groundwater in
Parcel B. The preferred soil cleanup alternative presented in the proposed plan involves excavating the
soils and treating them on site through a heating process called thermal desorption to remove volatile
organic compounds (VOC), as well as, solidification and stabilization treatment to address metal
contaminants. Treated soils would then be used as subbase foundation material for a landfill cap for Site
IR- 1/21, in Parcel E. The preferred groundwater cleanup alternative presented in the proposed plan
included a combination of deed restrictions prohibiting groundwater use, removal of steam and fuel lines,
lining portions of the storm drain system to prevent groundwater from entering the system and San
Francisco Bay, and long-term monitoring of the groundwater.
A public comment period was held from October 24,1996, to December 26, 1996. In response to
community requests for an extension, the comment period was extended 30 days beyond the initial public
comment deadline of November 25. A public meeting was held to present the proposed plan and receive
public comment on November 13, 1996. Written comments were also received from several
organizations.
Largely because of comments received by the community on the proposed plan, the Navy has selected a
different cleanup plan for soil within Parcel B. The groundwater cleanup plan remains the same as the
preferred alternative presented in the proposed plan, with the exception of transferring IR-25 to Parcel C.
The Navy and regulators are still discussing how to address groundwater contaminated with solvents
beneath the machine shop at IR-25. Therefore, to allow more time to address groundwater issues at IR-
25 and avoid delays in the cleanup and reuse of Parcel B, the Navy and the regulators decided to transfer
IR-25 to Parcel C. Groundwater and soil issues at IR-25 will be addressed as part of the proposed
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cleanup plan for Parcel C. The selected cleanup plan for Parcel B is described in the record of decision.
In brief, the selected cleanup plan for soil includes excavating the contaminated soils and transporting
them to off-site facilities for treatment and disposal.
2.0 BACKGROUND ON COMMUNITY INVOLVEMENT
The Navy has been conducting an active community involvement program at HPS since 1987 and has
initiated a wide range of activities. Numerous open houses, public meetings, and community workshops
have been held to explain the environmental cleanup process, discuss possible job opportunities, and
solicit community input on the Navy's approach to performing the cleanup at HPS. Fact sheets have
been sent to a community mailing list, including elected officials, community organizations and interest
groups, residents, and local businesses.
A community relations plan (CRP) was prepared in 1989 and recently updated in December 1996. The
CRP presents an outreach program to inform and involve the community in the cleanup decision-making
process. Two information repositories have been established to provide public access to detailed
information regarding environmental cleanup activities at HPS. The two repositories are located in the
San Francisco Main Library at the Civic Center, and the Anna E Waden Library, located at 5075 Third
Street, San Francisco. Additionally, an HPS administrative record, which includes documentation to
support the final cleanup decision, is located at the Naval Facilities Engineering Command in San Bruno,
California, and is available for public review.
The Navy has also established a restoration advisory board (RAB) composed of community members to
provide a forum for ongoing dialogue between the Navy, regulatory agencies, and the community on
environmental cleanup issues at HPS. The RAB includes a wide range of community members. The
goal of the RAB is to advise the Navy on its cleanup approach and review and comment on
environmental cleanup documents. RAB meetings are held monthly and provide an opportunity for
ongoing discussion between the Navy, regulators, and the community on cleanup activities underway at
HPS.
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3.0 PUBLIC COMMENTS AND NAVY RESPONSES
This section presents comments and questions received during the public comment period, as well as the
Navy's responses to those comments. The comments addressed in Sections 3.1 were received during the
public meeting (Section 3.1); comments addressed in Section 3.2 through 3.7 reflect written comments
received from representatives from the City and County of San Francisco (Section 3.2), the Coalition for
Better Wastewater Solutions (Section 3.3), the Innes Avenue Coalition (Section 3.4), ARC Ecology
(Section 3.5), Supervisor Leslie Katz (Section 3.6), and ECDC Environmental (Section 3.7).
The majority of comments received during the public comment period indicate significant community
concern regarding the use of the Parcel E landfill (IR-1/21) as part of the proposed remedy. Most
community members appear to support off-site disposal of Parcel B soils rather than the treatment of
soils and the use of treated soils as a cap for the IR-1/21 landfill.
Additional comments raised by several community members during the public meeting reflect concerns
about (1) possible impacts of HPS contaminants on bay fisheries and (2) the effectiveness of thermal
desorption as a treatment alternative. Other comments raised by individuals included concerns about
health risks associated with the groundwater, contracting procedures, transport of wastes associated with
implementation of the selected cleanup plan, and noise.
3.1 COMMENTS AND QUESTIONS FROM PUBLIC MEETING ON PARCEL B
PROPOSED PLAN, NOVEMBER 13,1996
The following summary reflects comments and questions raised during the public meeting that was
conducted by the Navy on November 13, 1996. The purpose of the public meeting was to (1) present the
proposed plan for Parcel B to the community, (2) respond to questions, (3) and receive community
comments on the proposed plan. Several comments and questions raised during the public meeting do
not directly relate to the Parcel B cleanup plan; nevertheless, those comments are also included. AM of
the following comments are summarized and do not present statements verbatim. Similar comments and
questions raised by several individual community members are summarized as one comment.
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3.1.1
IR-1/21 Landfill in Parcel E
1. Comment:
Response:
2. Comment:
Response:
3. Comment
Response:
Several community members raised questions regarding plans to address
contaminated groundwater from the IR-1/21 landfill in Parcel E and
whether the contaminated groundwater will be pumped into the City of San
Francisco's sanitary sewage system or stored on site. There appeared to be
a perception that the City's sewage system was connected to the HPS storm
water system.
These questions refer to a removal action currently underway at Parcel E that is
separate from the cleanup plan selected for Parcel B. The Parcel E removal
action involves installing an underground sheet piling wall to contain
contaminated groundwater from the landfill and prevent the groundwater from
migrating to the San Francisco Bay. Contaminated groundwater will not be
pumped into the city sewage system. It is important to note that the Navy's
storm water system is completely separate from the City of San Francisco's
sanitary sewage system.
Within Parcel B, groundwater beneath the machine shop at IR-25 is
contaminated with solvents; however, the Navy and regulators are still
discussing how to address groundwater issues at IR-25. To allow more time to
develop the most effective means to address these groundwater issues without
slowing the cleanup and eventual reuse of Parcel B, the Navy and the regulators
decided to transfer IR-25 from Parcel B to Parcel C. Groundwater contamination
and any associated soil contamination beneath IR-25 will be addressed as pan of
the proposed plan to cleanup Parcel C.
A question was raised regarding the percentage of treated soil from Parcel
B that will be placed in the Parcel E landfill.
The Navy's initial proposed cleanup plan for Parcel B involved using treated
soils from Parcel B as subbase foundation material for the Parcel E landfill cap.
If this plan is implemented, initial estimates indicated that approximately 80
percent of soil from Parcel B would have been used at the landfill following
treatment. In light of community concern, however, the Navy's selected remedy
does not include any use of the Parcel E landfill; instead,-soils will be shipped to
off-site treatment and disposal facilities. No percentage of treated soil from
Parcel B will be placed in Parcel E.
One community member asked what permitting process is required for the
Parcel E landfill and how long the landfill will exist This person also asked
what the cost differential is between cleaning, treating, and putting the
Parcel B soils in the landfill and cleaning, treating, and removing the soil off
site.
The Parcel E landfill is not an active landfill; therefore, no operating permit is
required. Furthermore, under CERCLA, permits are not required for on-site
cleanup actions. Finally, the life of the Parcel E landfill will depend on the
cleanup remedy selected for the landfill; a proposed cleanup remedy for the
landfill is expected to be presented to the public in December 1997.
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4. Comment:
Response:
5. Comment:
The estimated cost to treat the soils and use them as subbase foundation material
for a cap at the Parcel E landfill totals about $15.6 million. The estimated cost
presented in the Parcel B feasibility study to excavate and transport the soils to
an off-site facility for treatment (as necessary) and disposal totals about $11.2
million. However, the Navy is further evaluating costs in light of recent
reductions in the costs for transporting soils off site.
A question was raised about where soil from Parcel B would be stored until
it can be placed in the Parcel E landfill.
Soil excavated from Parcel B will not be placed in the Parcel E landfill; rather,
consistent with the selected remedy, it will be transported to off-site treatment
and disposal facilities. Storage areas to maintain the excavated soil pending
transport will be determined during development of the remedial design for
Parcel B. Storage areas that are centrally located and cause minimal impact to
HPS tenants will be identified. The storage areas will be designed to prevent
runoff and dust migration, in accordance with applicable laws.
One community member asked what areas are designated for landfills in
Parcel E.
Aside from the existing inactive landfill (IR-1/21), there are no designated areas
for landfills within Parcel E.
Response:
3.1.2 Hazards Associated with Fishing
6. Comment:
Response:
Many community members raised concerns that deformed fish were found
off the coast of HPS. These community members asked if the Navy has
investigated whether contaminants from HPS were impacting the fisheries
in San Francisco Bay and requested that the Navy prohibit fishing off
shipyard property.
The Navy and the regulators are not aware of any incidences of deformed fish
found near HPS. The Navy is conducting an ecological risk assessment to assess
potential risks to birds and marine life in the offshore area from exposure to
contaminants present at HPS. However, the ecological risk assessment will not
include an evaluation of fish that swim offshore of the shipyard because fish
migrate throughout the San Francisco Bay and may be impacted by many
different industries around the Bay. As many of the industrial operations around
the Bay involve similar types of chemicals, the Navy would be unable to directly
correlate impacts on the fish to contaminants at HPS. The ecological risk
assessment instead focuses on identifying potential sources of contamination
within the shipyard to the Bay and determining the possible impact on receptors,
such as shellfish, that continually live in the offshore area. By addressing the
on-site sources of contamination and minimizing the impact on the offshore
receptors, contamination from HPS that may impact fish swimming offshore
should also be minimized.
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Additionally, a group of ecological assessment specialists from the San
Francisco Bay Area regulatory agencies are currently evaluating how to address
impacts to fish and marine life within the Bay on a region-wide basis.
It is important to note that the Navy prohibits fishing from HPS. To further
discourage fishing off the shore, the Navy has posted signs facing the Bay in four
languages (Spanish, Chinese, Vietnamese, and English) in about 50 locations
along the shoreline within HPS. The City of San Francisco has also posted signs
along the waterfront in 14 locations, extending from Fort Point beneath the
Golden Gate Bridge to Candlestick Park, to warn people against eating fish
caught in San Francisco Bay.
3.1.3 Contracting Procedures
7. Comment: One community member asked about contracting procedures for
developing the remedial design and whether the Navy plans to include
minority environmental companies.
Response: The remedial design will be developed under the Comprehensive Long-Term
Environmental Action Navy (CLEAN) Contract, the Navy's primary cleanup
contract. The CLEAN contract includes goals to contract 35 percent of its work
to small business concerns, of which 20 percent is to be subcontracted to small
disadvantaged businesses (SDB). Additionally, the Navy continues to seek local
and minority-owned businesses to participate in the environmental cleanup
program at HPS. Toward that end, the Navy has hired Business Development
Inc. (BDI), a local SDB firm that specializes in Hunters Point development and
job opportunities. BDI works closely with the Navy and the Navy's contractor
to identify local businesses to participate in the cleanup process.
3.1.4 Transport of Wastes Off-Site
8. Comment: One questioner asked for clarification on the advantages of treating the soil
on site compared to excavating and transporting the soil to an off-site
certified disposal facility, particularly with regard to long-term °
effectiveness.
Response: Based on the Navy's initial evaluation of soil cleanup alternatives, on-site
treatment seemed to be the preferable option for several reasons. On-site
treatment would permanently reduce the toxicity, mobility, and volume of
contaminants contained in the soils (consistent with the U.S. Environmental
Protection Agency's [EPA] nine criteria against which alternatives must be
evaluated); cause less disruption to the community associated with trucks
transporting wastes off-site; and would not add to a growing national problem of
limited landfill capacity. Furthermore, regulatory agencies have expressed a
preference for on-site treatment. A detailed discussion of how this alternative
meets each of EPA's nine criteria is presented on pages 32 and 33 of the Parcel
B proposed plan.
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9. Comment:
Response:
Cost comparisons of cleanup alternatives for Parcel B have been reevaluated
because of recent reductions in costs for transporting Parcel B wastes to off-site
treatment and disposal facilities. In light of the new cost information as well as
community concerns expressed during the comment period, the Navy has
selected off-site treatment and disposal as the cleanup remedy for Parcel B.
Advantages associated with transporting the soil to off-site treatment and
disposal facilities are highlighted on page 25 of the proposed plan: the selected
remedy meets EPA's nine criteria, costs less than the other cleanup alternatives,
provides more protection to on-site workers, and is responsive to community
concerns regarding onsite treatment and disposal.
One community member asked how many trucks will be transporting
wastes through the Hunter's Point community and noted a preference for
transporting wastes off site by rail or barge rather than trucks.
It is anticipated that a total of about 36,600 cubic yards of soil will be excavated
from Parcel B and transported to off-site treatment and disposal facilities. Given
that an average truckload carries about 15 cubic yards, it is estimated that a total
of about 2,400 truckloads will be necessary. The Navy is currently exploring
options for transporting the soil by rail or barge rather than by truck.
3.1.5
Noise
10. Comment:
Response:
3.1.6
One community member raised concern about noise associated with
cleanup equipment; this member asked about the specific time period such
equipment will be used and the noise level that can be expected.
The equipment used to excavate soils from Parcel B (consistent with the selected
remedy) will include backhoes. The soils will be shipped by truck or rail to off-
site treatment and disposal facilities. Anticipated noise levels will be
comparable to a construction site at which a building foundation is being
excavated. The cleanup operations will occur during the daylight hours, Monday
through Friday, over a 3- to 6-month period. The cleanup operations are
expected to start in the Spring 1998. The specific schedules for construction will
be detailed in the remedial action work plan.
Public Comment and the Decision-Making Process on the Proposed Plan for
Parcel B
11. Comment:
Response:
12. Comment:
A request was made for a 30-day comment period extension on the
proposed plan for Parcel B to allow the community the opportunity to
prepare meaningful comments on the Parcel B proposed plan.
The Navy extended the public comment period by 30 days, to December 26,
1996.
One community member asked what happens when the record of decision is
published.
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Response:
13. Comment:
Response:
The record of decision presents the final cleanup plan for Parcel B that was
selected in light of public comments on the proposed cleanup plan and other
National Contingency Plan criteria. A responsiveness summary that addresses
public comments on the proposed cleanup plan is included with the record of
decision. Once the ROD is signed, the Navy will publish a notice of availability
in the local newspapers and will begin designing the cleanup remedy.
One community member asked who would make the final decision about
the cleanup remedy.
The Navy, in partnership with the EPA and the State of California Department of
Toxic Substance Control, makes the final decision on the cleanup remedy.
3.1.7
Effectiveness of Thermal Desorption and Solidification and Stabilization Treatment
Technologies
14. Comment:
Response:
15. Comment:
Response:
One individual expressed support for on-site treatment versus off-site
disposal. This same individual questioned whether the numbers used in the
Parcel B feasibility study to calculate costs for use of thermal desorption
were based on low temperature thermal desorption, asserting that high
temperatures will be necessary at Parcel B. As a result, the costs of using
thermal desorption are underestimated in the Parcel B feasibility study.
The Navy believes its cost estimates for using thermal desorption are accurate.
Cost calculations were based on high temperature application of thermal
desorption. The estimates are based on costs associated with previous thermal
desorption applications in environmental conditions similar to those at Parcel B
and involved heavy hydrocarbon contamination and high temperatures. EPA
guidance requires that cost estimates for proposed cleanup remedy presented in
the feasibility study are within a range of 30 percent less and 50 percent more
than the actual cost of a given remedy. EPA's guidance allows such a range in
cost estimates to address cost uncertainties associated with use of innovative
cleanup technologies.
Furthermore, it is important to note that if thermal desorption treatment was
included in the selected remedy for Parcel B, the vendor implementing the
treatment would have to achieve specified cleanup levels before receiving
payment. Nevertheless, the final remedy selected for Parcel B does not include
thermal desorption treatment.
A question was raised about why thermal desorption is considered an
effective alternative at Parcel B when it has been rejected for Parcel D.
The final cleanup remedy for Parcel D has not yet been selected. Treatment of
the soil through thermal desorption is not included in the selected remedy for
Parcel B. The types and concentrations of contaminants at Parcels B and D are
different. Different thermal desorption systems have been developed to treat
different types of contaminants under different environmental conditions. For
example, some thermal desorption systems have been developed to treat lighter
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hydrocarbons, such as gasoline present within Parcel D; such treatment would
require lower temperatures than those systems designed to treat heavy
hydrocarbons such as the polyaromatic hydrocarbons (PAH) and semi-volatile
organic compounds (SVOC) present in Parcel B. For example, lower
temperatures necessary to treat Parcel D wastes would range from 500° to 800°
(F) and high temperatures up to 1,400° (F) would be necessary for Parcel B
wastes; therefore, there is no direct comparison between using thermal
desorption at Parcel B and Parcel D. Furthermore, any technology selected will
be subject to performance pilot tests to ensure that the technology will achieve
the cleanup goals.
Comments regarding remediation of Parcel D will be considered during the
public comment period on the proposed cleanup plan for Parcel D, expected to
be submitted to the public in May 1997.
The proposed plan should present performance data on thermal desorption
and solidification and stabilization treatment technologies that indicate
their effectiveness relative to the cleanup levels selected for Parcel B.
Response: As the proposed plan is designed for the general public, it does not provide
detailed information such as performance data. Rather, consistent with EPA and
state guidance, the proposed plan describes each proposed cleanup alternative
and whether and how they satisfy EPA's nine evaluation criteria. Performance
data on thermal desorption and solidification and stabilization treatment
technologies are presented in the feasibility study on pages 3 to 31 and 5 to 42
(thermal desorption) and 3 to 28 and 5 to 59 (solidification and stabilization).
The feasibility study was presented to the HPS RAB and copies were made
available to the RAB as well as placed in the HPS public information
repositories.
3.1.8 Potential Health Effects
16. Comment:
17. Comment:
Response:
18. Comment:
Response:
One community member asked what assurances exist to prohibit use of
groundwater for drinking, growing vegetables, or private consumption and
who will monitor and enforce such prohibitions.
The Navy currently restricts use of the groundwater for any purpose and
prohibits any wells from being drilled within HPS. As part of the groundwater
remedy, the deed of transfer will include restrictions on use of the groundwater.
The State will be responsible for enforcing those restrictions.
One individual asked how groundwater vapors will be contained to prevent
exposure to humans or animals.
The only area where potential volatilization from groundwater could occur and
produce vapors that pose a risk to human health is the groundwater beneath the
machine shop within IR-25 which is contaminated with solvents. The Navy and
regulators are still discussing how to address groundwater issues at IR-25. To
allow more time to develop the most effective means to address these
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3.1.9
groundwater issues without slowing the cleanup and eventual reuse of Parcel B,
the Navy and the regulators decided to transfer IR-25 from Parcel B to Parcel C.
Groundwater contamination and any associated soil contamination beneath IR-
i 25 will be addressed as part of the proposed plan to cleanup Parcel C.
Miscellaneous Questions
19. Comment:
Response:
20. Comment:
Response:
21. Comment:
Response:
22. Comment:
Response:
23. Comment:
Response:
A question was raised about whether the soil will be treated at a depth of 10
feet below the surface and whether that that depth reaches the groundwater
table.
Sites IR-7 (the subbase area) and IR-18 (waste disposal area) were the only areas
within Parcel B where contaminants were detected below 10 feet; therefore, soil
will be excavated at those two sites down to the groundwater table to prevent
contaminants from migrating into the groundwater.
One individual asked why soils from Parcel B needed to be taken to
hazardous waste facility if they are treated and cleaned.
Approximately 20 percent of the soils excavated from Parcel B will be sent
directly to a treatment and disposal facility that handles strictly hazardous waste.
The remaining 80 percent of soils from Parcel B will include some clean soils as
well as some soils that are less hazardous but still require some treatment. Under
the selected cleanup plan, soils will be excavated and sent to off-site treatment
and disposal facilities where they will be toxicity tested and treated and disposed
of according to federal and state requirements.
A question was raised about whether any machinery can be salvaged from
Parcel B for industrial use.
All unusable machinery has been transported from HPS for salvage or reuse.
A question was raised about who will monitor the construction crews when
the land is developed for future use.
Any future reuse of HPS property will be the responsibility of the San Francisco
Redevelopment Agency. Contaminated soils will be removed by the time the
property is developed for future use. Potential risks associated with the
groundwater will be addressed by including restrictions on groundwater use in
the deed of transfer. As necessary, the Redevelopment Agency will require
construction workers to take protective measures to prevent risks to on-site
workers and tenants near the area of construction.
A question was raised regarding the cost to cleanup Parcel B and who will
pay for the cleanup.
The cost of the selected cleanup remedy totals about $14.8 million: $11.2 million
is for the soil remedy, and $3.6 is for the groundwater remedy. The Navy will
pay for the cleanup, as required by CERCLA.
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3.2 COMMENTS FROM CITY AND COUNTY OF SAN FRANCISCO, DEPARTMENT OF
PUBLIC HEALTH, BUREAU OF ENVIRONMENTAL HEALTH MANAGEMENT
1. Comment:
Response:
2. Comment:
Response:
3. Comment:
Response:
As part of the remediation of groundwater, the Navy has stated that it will
line portions of the storm water pipes. Our concern is that this effort
should be coordinated with the San Francisco Redevelopment Agency and
its plans to replace any if not all of the utilities at the shipyard. If replacing
the pipes can provide the same level of environmental protection as lining
the pipes then taxpayer's money will not have to be spent twice on lining the
pipes and then later replacing them.
The Navy does not plan on replacing any utilities; rather, as necessary, the Navy
will repair existing utilities to prevent migration of contaminants from the site to
the Bay. Utilities could not be replaced until the City's redevelopment plans are
certain. Definitive redevelopment plans cannot be made until adequate funding
is generated through new businesses located at HPS. As it is still unclear when
such funds would be available, the Navy plans to move forward in the meantime
and repair the utilities, to expedite transfer of HPS.
The Navy should manage the treated soil so it is consistent with the reuse of
the landfill (IR Site 1/21) at Parcel E or wherever the treated soil will
ultimately be placed. Although the Health Department does realize that
restrictions may be placed on Parcel E, we want to ensure that future
disposal actions at the landfill are not the cause of additional and
burdensome restrictions.
The Navy's initial proposed cleanup plan for Parcel B involved using treated
soils from Parcel B as subbase foundation material for the Parcel E landfill cap.
The Navy's selected remedy does not include any use of the Parcel E landfill;
instead, soils will be shipped to an off-site landfill.
The remediation includes groundwater monitoring which will require
tracking of monitoring wells for 30 years. The Department of Health would
like the Navy to have in place a plan to manage the tracking of these wells
and to be notified of who within the Navy is responsible for the tracking of
these wells so they are not "lost" or "damaged" during future construction
and reuse of the parcel.
When the Navy transfers HPS to the City, documentation will be provided to
identify the location of all wells installed during the remedial investigation and
feasibility study, as well as during the remedial action. As part of the transfer of
property, the Navy and the City will address how to handle future monitoring of
the wells. The Navy plans to monitor the groundwater for 30 years following
completion of the remedial action.
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3.3 COMMENTS FROM THE COALITION FOR BETTER WASTEWATER SOLUTIONS
1. Comment:
Response:
2. Comment:
Much of the Navy's preferred alternative for toxic soils in Parcel B is based
on treating the contaminated soil and leaving it on-site to cap a landfill that
is already a toxic site within the Hunters Point Naval Base. Yet, the
proposed plan doesn't address the long-term impacts of this very critical
policy of maintaining a toxic site on the base. It would seem that a much
more thorough study of capping of this toxic landfill needs to be conducted
regarding the impacts on groundwater, the impacts on the Bay's surface
water in the event of normal subsurface migration, or in the event of
liquefaction during a seismic event, the impacts on humans in adjacent
land-uses, including the Golden Gate Railroad Museum where increasing
amounts of children and adults circulate, and the impacts on residents
nearby who would be exposed if somehow toxic groundwater backed up
into their neighborhoods as a result of capping and sealing off of the current
access of polluted water into the Bay.
The Navy's initial proposed cleanup plan for Parcel B involved using clean and
treated soils from Parcel B as subbase foundation material for the Parcel E
landfill cap. The treated soils would have been cleaned to a level protective of
San Francisco Bay. The initial proposed plan was consistent with EPA's
guidance on landfill "presumptive remedies." EPA's presumptive remedy for
landfills involves capping and containment of the groundwater. The initial
proposed plan was not designed to increase the size of the Parcel E landfill;
rather, only clean and treated soils would have been used to provide subbase
foundation material for the Parcel E landfill. With respect to contaminated
groundwater leaching from the landfill, the Navy is currently conducting an
action to install an underground sheet piling wall to contain the groundwater and
prevent grounndwater from seeping in or out of the contained area. This action
is also consistent with EPA's presumptive remedy for landfills.
In light of community concerns and recent reduction in costs associated with
transporting the wastes to off-site facilities, however, the Navy has reevaluated
the soil cleanup alternatives and selected a remedy that does not include any use
of the Parcel E landfill. Soils will instead be shipped to off-site treatment and
disposal facilities. Concerns about how to address the Parcel E landfill,
including geotechnical concerns and exposure scenarios, will be evaluated
during the feasibility study for Parcel E.
Public comments regarding measures to remediate the Parcel E landfill will be
considered during the public comment period on the proposed plan for Parcel E
and addressed in the responsiveness summary that will be part of the record of
decision for Parcel E. The proposed plan for Parcel E is expected to be
completed and made available to the public for comment December 1997.
Why doesn't the proposed plan more thoroughly address the long-term
impacts of capping and leaving in place the toxic material in the landfill at
IR-1/21?
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Response:
3. Comment:
Response:
4. Comment:
Response:
5. Comment:
The proposed plan for Parcel B focuses only on options to clean up Parcel B; it
does not address possible cleanup options for other parcels within HPS, such as
Parcel E. The Parcel E landfill was discussed in the Parcel B proposed plan only
as part of an option for handling Parcel B soils. As the proposed plan explains,
before such an alternative can be implemented, the Navy would have thoroughly
evaluated the long-term impacts from the Parcel E landfill. Use of the Parcel E
landfill is no longer part of the selected remedy for Parcel B, however, and
comments regarding the landfill will be considered during the public comment
period on the proposed plan for Parcel E.
Although you may "cap" the top of the landfill and even dam off the access
of groundwater to the Bay, how do you prevent the rising and falling water
table below the toxic site from constantly "bathing" the landfill's toxic
waste in water and creating even more toxic leachate from the soluble
contaminants already in the capped landfill? In essence, can you really
prevent the continued long-term pollution of groundwater and surface
waters from such a low-lying toxic site? Doesn't this really necessitate an
upland disposal solution?
As noted in the response to comment 1, an underground sheet piling wall is
being installed to prevent the movement of groundwater from beneath the
landfill and to prevent infiltration of groundwater into the landfill. Options for
addressing the Parcel E will be evaluated in the Parcel E feasibility study and
will include consideration of hydrogeological and geotechnical concerns.
Why isn't the Navy looking at eliminating the toxic landfill from Hunter's
Point altogether? Isn't it a waste of taxpayer's money and a missed
opportunity when you don't try to truly "clean" this site, but rather move
toxic wastes from one part of the Hunters Point site to another in kind of a
"pollution shell game?"
These comments refer to measures to remediate the Parcel E landfill. The Navy
will consider this comment as it evaluates alternatives to address the landfill.
Because of the complexities of moving landfills as well as EPA's presumptive
remedy for landfills (see the response to comment 1), the Navy initially
concluded that a cap may be appropriate for the Parcel E landfill. The Navy will
evaluate capping as just one alternative among other cleanup alternatives in the
Parcel E feasibility study. The public will have the opportunity to comment on
cleanup alternatives for Parcel E when the Parcel E proposed plan is completed
in December 1997.
Has the Navy and its consultants considered or economically evaluated the
clean-up of the existing toxic site and the conversion of it to a wetland which
could forever improve the water quality and environment of San Francisco
Bay? Is there a "deep-pocket" generators) besides the Navy, who used the
toxic landfill in the past and could be a principal responsible party for its
clean-up? If so, shouldn't the Navy pursue a cost-sharing from the
responsible party so that this toxic site is not left sitting along the Bay for
future generations?
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6. Comment:
Response: These comments refer to measures to remediate the Parcel E landfill and will be
considered during the public comment period on the proposed plan for Parcel E.
As the cleanup process continues, the Navy will evaluate the liability of other
potentially responsible parties.
The proposed plan recommends spending almost $22 million on the
preferred alternatives, but there doesn't seem to be a commensurate
environmental improvement from that expenditure. Instead, treated
contaminated soils are still left on-site above a toxic waste site that is
proposed to remain along the Bay and be monitored by high-priced
consultants for 30 years or more. Although some groundwater will be
pumped and cleaned, the groundwater under the toxic waste site will
continue to "bathe" the toxins and created more polluted groundwater.
Response: The initial proposed cleanup plan for Parcel B would have involved the use of
only clean and treated soils for subbase foundation material for the Parcel E
landfill; the initial proposed cleanup plan was not designed to increase the size
of the Parcel E landfill. As noted above, before the initial Parcel B proposed
plan could have been implemented, the Navy would have thoroughly evaluated
the long-term impacts from the Parcel E landfill and alternatives for addressing
the landfill. As noted in the response to comment 1, the selected remedy no
longer includes use of the Parcel E landfill, and steps are underway to contain
groundwater migration around the landfill.
What do you really gain by a proposed plan that keeps all these toxics
remaining on the Hunters Point site? What would be the price to remove
them to an upland facility that is away from population centers and is
designed with a geology, hydrology, climate and other factors that make it
much more appropriate than adjacent to the Bay? Can it really be that
much more expensive than $22 million and wouldn't the benefits far
outweigh the costs? Can it be done safely without trucks running through
the neighborhoods?
Response: See the response to comment 1; the selected remedy no longer includes use of
the Parcel E landfill. Issues such as costs associated with shipping landfill
wastes to off-site disposal facilities will be addressed in the Parcel E feasibility
study.
If a solution for removal from the site and upland disposal away from
Hunters Point residents is no more expensive than the preferred alternative
of on-site disposal, what rational does the Navy have (besides prolong high-
priced consultant contracts) for not accepting that as a superior alternative?
Response: The initial proposed plan for Parcel B soils included on-site treatment and
disposal; however, the selected remedy no longer involves on-site treatment and
disposal: it includes shipment of Parcel B soils to off-site certified disposal
facilities. The estimate for the soil remedy is approximately $11.2 million.
7. Comment:
8. Comment:
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3.4 COMMENTS FROM THE INNES AVENUE COALITION
1. Comment:
Response:
Comment:
Response:
Comment:
Response:
4. Comment:
The proposed alternative establishes that some of the cleaned soil from
Parcel B will be used to "cap" contaminated soil on Parcel E. However, this
assumes decisions concerning Parcel E (that the contaminated soil can be
capped successfully), which, to the best of my knowledge, have not been
made. Does approval of this plan give tacit approval to leaving
contaminated soil in Parcel E?
No. The preferred alternative for soil presented in the Parcel B proposed plan
would have been contingent on the final cleanup remedy selected for the Parcel
E landfill. The final cleanup remedy for Parcel E cannot be selected until the
public has the opportunity to comment on all cleanup alternatives considered for
the Parcel E landfill. Following public comment, the Navy, in consultation with
the regulatory agencies, will determine the best alternative for the Parcel E
landfill.
While the proposed alternative provides the "solution" of using the cleaned
soil as a cap, it says nothing about the timeline for these procedures. What
will be done with the "clean" soil while it is waiting to be used on Parcel E?
The preferred alternative initially proposed for Parcel B would have involved
storing the treated soil on site until a final remedy is selected for Parcel E. The
storage location would have been determined during development of the
remedial design.
The proposed alternative uses technology that cleans much of the
contaminated soil on site but it says nothing about the parameters of the
work involved. What is the noise level of the machinery involved? Will the
work be done according to San Francisco City and County construction
ordinances for sound and safety so close to a residential neighborhood?
The selected remedy does not include on-site treatment; instead, soils will be
excavated and transported by either truck or rail to permitted off-site treatment
and disposal facilities. The equipment used to excavate and transport soils from
Parcel B will include backhoes. Anticipated noise levels will be comparable to a
construction site at which a building foundation is being excavated. The cleanup
operations will occur during the daylight hours, Monday through Friday, over a
3- to 6- month period. The cleanup operations are expected to start in the Spring
1998. Construction work will be conducted in accordance with applicable city
and county construction ordinances.
The proposed alternative states that a great deal of both contaminated and
cleaned soil will be hauled away and additional clean soil will be brought in
to fill holes, all by truck. My estimates are that more than 10,000 truck
round trips will be needed to haul all of this soil to and from the HPS
during the course of all cleanup. Considering that the only access to the
HPS is one residential street (Innes Avenue), why haven't alternative
transportation methods be considered? Furthermore, all transportation
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5. Comment:
experts state that trucking is the most expensive hauling method. There is a
railhead at the HPS, rail is less expensive than trucking, is rail being
considered? The HPS is on the bay, is barge being considered?
Response: It is anticipated that a total of about 36,600 cubic yards of soil will be excavated
from Parcel B and transported to off-site treatment and disposal facilities. Given
that an average truck!oad carries about 15 cubic yards, it is estimated that a total
of about 2,400 truckloads will be necessary to remove the soil. Approximately
the same amount of clean fill will be used to backfill the excavated area. The
Navy is currently exploring options for transporting the soil by rail and barge
rather than by truck to avoid transporting the soils through the Bayview
community.
The proposed alternative provides no information concerning proper
compensation or even notification for the current HPS tenants or the
adjacent neighborhood during rehabilitation. What plans are being made
for notification and compensation to shipyard tenants and to residents and
businesses on Innes Avenue during this work?
Response: Steps will be taken to minimize the noise and impact to HPS tenants and nearby
residents and businesses. For example, operating hours will be restricted to
regular work hours and dust suppression steps will be taken. Additionally,
tenants will be notified of planned actions and any associated precautionary
measures that may be necessary. As previously noted, the Navy is currently
evaluating options to transport Parcel B soils by rail rather than truck to avoid
hauling the soils through the Bayview community. Shipyard tenants and
residents living adjacent to HPS will be notified before on-site construction
begins.
COMMENTS FROM ARC ECOLOGY
Use of the Parcel E Landfill
1. Comment:
It's too early to presume availability of the Parcel E Landfill.
The preferred alternative assumes that soils treated by thermal desorption
and/or soil solidification/stabilization will form the foundation layer for a
cap at the Parcel E landfill. Arc Ecology believes that the Navy owes it to
the surrounding community to do a much more thorough analysis of the
consequences of retaining the landfill on Parcel E before any plans are
made to deposit more material upon it.
If the Navy wishes to include the Parcel E landfill in proposed remedies for
other parcels, we ask that the Navy prepare and circulate a site-specific
RI/FS/Proposed Plan/ROD. Until this is done, or until the landfill issues are
resolved during existing Parcel E CERCLA process, we oppose placement
of new material at this site. Furthermore, we oppose stockpiling large
quantities of soil for an extended period, in anticipation of the Parcel E
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landfill being capped. If the Navy chooses to stockpile soils as part of the
Parcel B remedy, then the potential consequences to the community and the
ecosystem must be thoroughly evaluated.
Response: The Navy did not intend to place any soil on the Parcel E landfill until cleanup
alternatives for the landfill had been fully evaluated and the public had a chance
to comment on those alternatives. Treated soil would only be placed on the
landfill if the final selected remedy involved capping the landfill. Any
stockpiling of soil would have included measures to protect on-site workers and
tenants as well as the environment. The soils would have been treated to cleanup
levels protective of San Francisco Bay, and the storage areas would be contained
to prevent runoff and dust migration in accordance with applicable laws.
The Navy's selected remedy no longer includes any use of the Parcel E landfill;
instead, soils will be shipped to off-site treatment and disposal facilities.
Comments regarding measures to remediate the Parcel E landfill will be
considered during the public comment period on the proposed plan and
addressed in the responsiveness summary included as part of the record of
decision. The proposed plan for Parcel E is expected to be completed and
submitted to the public for comment December 1997.
Excavation
2. Comment:
Response:
3. Comment:
VOC control during excavation needs more evaluation or explanation.
The Proposed Plan states that alternative S-6 would involve excavating soils
for which emissions of VOCs may be difficult to control. Please elaborate.
How would VOCs be controlled during excavation? What additional costs
might be associated with VOC control during excavation? Could
volatilization of SVOCs, including PCBs, also be an issue? Why or why
not?
The Proposed Plan does not state that alternative S-6 would involve excavating
soils for which emissions of VOCs may be difficult to control. It is very unlikely
that VOC emissions at hazardous levels will occur during excavation of Parcel B
soil. However, to be protective, air monitoring equipment will monitor the levels
of VOCs (if any) at the excavation locations and at the perimeter of IR site
boundaries where excavation has occurred during the excavation. In the unlikely
event hazardous VOC emissions are detected during excavation, control actions
will be taken to protect workers, tenants, and the community. SVOCs and PCB
volatilization during excavation should not be an issue because excavation
conditions, such as ambient temperature, are not sufficient to volatilize these
contaminants.
Soil dewatering needs to be more thoroughly analyzed.
Groundwater is encountered at fairly shallow depths on Parcel B. How
would soils be dewatered and/or dried prior to treatment? How would
potential VOC emissions from drying soil be evaluated and controlled?
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How would wastewater be collected, tested, and disposed of? Were costs
associated with treatment dewatering included in the cost estimates? What
would be the effect on costs and performance if soils are not dried prior to
thermal desorption treatment?
Response: Soil would be dewatered on site by air drying; the process may be enhanced by
using fans. In the unlikely event high levels of VOC emissions occur, the
emissions can be controlled by conducting drying within a closed temporary
structure or building. Individual excavations will be dewatered by pumping.
Collected water will be placed in a tank, sampled, and discharged to an
appropriate treatment facility, if necessary. As discussed on page 5-43 of the
Draft Final Parcel B Feasibility Study, if soils are not dried prior to thermal
desorption treatment, additional fuel costs will be incurred to dry the soil.
Proposed Treatment
4. Comment:
Response:
5. Comment:
Response:
Leachability tests for stabilized soils need more explanation.
Will the Navy mix soils from many sources prior to collecting samples for
teachability tests? How large will the stockpiles be from which samples are
drawn? Are there regulatory guidelines as to how many samples must be
taken from the stabilization process and how they must be analyzed? What
kind of analysis will be used to ensure long-term stability of treated soils?
Stabilization is a technology by which soil and additives are mixed to bind
contaminants within a cement-like product. Soil from different locations would
be mixed as pan of the stabilization process. Soils would be stockpiled
according to the types of contaminants they contain and then subject to a
performance pilot test to ensure the stabilization technology achieves the cleanup
goals. Samples for teachability testing would likely be collected based on the
volume of treated material generated, rather than the number of stockpiles
created.
Soil stabilization is no longer included in the selected remedy; instead the
selected remedy includes excavating the soils and transporting them to an off-
site facility for treatment and disposal.
Costs and consequences associated with off-site disposal of solidified soils
should be presented.
How much more would it cost if stabilized soils must be disposed of at an
off-site landfill? It seems to me that costs of off-site disposal of stabilized
soil could be very high, perhaps an additional half- to one million dollars.
(Estimate calculated by: 25063 cy * 13 bulking factor /17.4 cy/tnick) *
310.75 $/truckload = $581,887 + $50,000 for disposal fees). How would
these soils be moved off-site?
As noted, soil stabilization is no longer included in the selected remedy. The
total estimated cost to excavate and transport Parcel B soils to an off-site facility
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6. Comment:
Response:
for treatment and disposal is about $11.2 million. The Navy is currently
evaluating options to transport the soils off site via truck, rail, or barge.
Thermal desorption technology is oversold.
What level of effectiveness can be achieved by the proposed thermal
desorption technology for Parcel B chemicals of concern, particularly for
PCBs? The EPA SITE data we've seen shows much higher residual levels
for PCBs than Hunters Point target cleanup levels for Parcel B. This
implies that treated soils anticipated to be disposed of at the Parcel E
landfill will be contaminated above Parcel B target cleanup levels.
Furthermore, we understand that treatment of the "fines" in thermal
desorption units can be a problem, even when they are run back through
the treatment unit. Please provide more information about typical
problems encountered with high-temperature thermal desorption treatment
and assess the level of cleanup possible using thermal desorption of Parcel B
soils.
What is the contingency plan should treatability studies conclude that
thermal desorption will not achieve an appropriate level of cleanup?
What sort of stack gas emissions and fugitive dust emissions are typical of
high temperature thermal desorption units? What air emission
performance standards would apply? What sort of technologies would be
used to control stack emissions?
Treating PCBs by thermal desorption requires high operating
temperatures, in the range of 1200 degrees Fahrenheit. This temperature is
above the boiling points for arsenic, mercury, and thallium. How effectively
can these volatilized metals be removed from stack gasses.
The initial proposed cleanup plan for Parcel B included soil treatment through
thermal desorption, coupled with. The selected remedy for Parcel B does not
include use of thermal desorption or solidification and stabilization, nor does the
selected remedy involve the use of the Parcel E landfill. Instead, soils will be
shipped to off-site treatment and disposal facilities.
Environmental conditions at Superfund Innovative Technology Evaluation
(SITE) demonstration locations are not necessarily the same as Parcel B
conditions. The initial proposed plan called for using treated soils from Parcel B
as subbase foundation material for the Parcel E landfill. The treated Parcel B
soils would have to meet the IR-1/21 placement criteria of protection of the San
Francisco Bay. Furthermore, it is important to note that if thermal desorption
treatment was included in the selected remedy for Parcel B, the vendor
implementing the treatment would have had to achieve specified cleanup levels
before receiving payment.
Thermal desorption would be used to treat soils containing VOCs and combined
VOCs and inorganics. If thermal desorption-treated soil, including fines, does
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7. Comment:
Response:
8. Comment:
Response:
not meet cleanup criteria, it will either be transported off site for disposal or
further treated by solidification and stabilization.
The vendor implementing the thermal desorption treatment would be made
aware of the soil contaminants and the emission requirements for such
contaminants. The vendor would be required to prove that compliance with
required regulations is achievable.
The costs estimated for thermal desorption treatment seem low.
The cost estimate for the preferred alternative seems low. The Feasibility
Study states that high temperature thermal desorption must be used to treat
the SVOCs. Yet, the cost estimate worksheets in Appendix E of the
Feasibility Study use $91/ton to estimate costs for low-temperature thermal
desorption. According to EPA's SITE documents, the cost of a high-
temperature unit ranges from $100 to $400 per ton of soil with the high end
being typical of units treating PCBs. Using these unit cost factors would
increase the cost of cleanup by $159,000 to $3,687,000.
How would the Navy respond if costs associated with the preferred
alternative were overrun by a significant amount over the contingency?
How would costs of off-site disposal be covered if it became necessary some
time during the remediation effort?
As noted in the response to comment 6, environmental conditions at SITE
demonstration locations are not necessarily the same conditions as Parcel B
conditions. The Navy believes its cost estimates for using thermal desorption are
accurate. The Navy's cost estimates are based on discussions with various
thermal desorption vendors who were made aware of the Parcel B soil
contaminants. EPA guidance requires that cost estimates for proposed cleanup
remedy presented in the feasibility study are within a range of 30 percent less
and 50 percent more than the actual cost of a given remedy. EPA's guidance
allows such a range in cost estimates to address cost uncertainties associated
with use of innovative cleanup technologies.
Nevertheless, the remedy selected for Parcel B does not include thermal
desorption treatment.
Overall, we support remedial actions at Hunters Point Shipyard that help to
restore the area to the condition in which the Navy found it. Our
preference is for remedial actions that do not require the Navy to carry out
long-term maintenance and monitoring at the Shipyard. Not only does this
strategy assure the community that the site, and the surrounding ecosystem,
will remain safe, but it also allows the City flexibility in planning reuses that
benefit and enhance the neighboring community.
The Navy also supports remedial actions that restore the area to beneficial use as
well as require minimal long-term maintenance and monitoring. Remedial
actions selected for each site within HPS will depend on the nature and extent of
contamination as welj as appropriate remedial technologies currently available.
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3.6 COMMENTS FROM LESLIE KATZ, BOARD OF SUPERVISORS, CITY AND
COUNTY OF SAN FRANCISCO
1. Comment:
Response:
2. Comment:
Response:
From what I understand, the landfill that the Navy plans on using is already
a toxic site within the Hunters Point Naval Base. Since the Naval Base is in
a major City, and the City is hoping to use this land to enhance the
neighboring communities, it does not appear to make sense to maintain a
toxic site on the Base. It seems to me that a much more thorough study of
capping this toxic landfill needs to be conducted before a decision is made.
This is especially of concern regarding impacts on groundwater, the Bay
Area's surface water, and humans in the adjacent area.
The Navy's initial proposed cleanup plan for Parcel B involved using treated
soils from Parcel B as subbase foundation material for the Parcel E landfill cap.
In light of recent reductions in costs associated with transporting Parcel B wastes
to off-site facilities, as well as community concerns, the Navy's selected remedy
no longer includes any use of the Parcel E landfill; instead, soils will be shipped
to off-site treatment and disposal facilities. The ultimate decision on how to
address the Parcel E landfill will be evaluated in the Parcel E feasibility study.
The proposed plan for Parcel E will include cleanup options for Parcel E and
will be made available to the public for comment in December 1997.
Although the proposed plan recommends spending $22 million on the
preferred alternatives, there does not appear to be a commensurate
environmental improvement from that expenditure. I am concerned that
the treated contaminated soils are still left onsite above a toxic waste site
that is proposed to remain along the Bay for at least 30 years. In addition, I
question why the Navy would want to keep all these toxins remaining on the
Hunters Point site. It would seem wiser to remove these toxins and place
them in a facility that is away from the population centers .
The Parcel E landfill is no longer included in the selected remedy for Parcel B.
Comments and concerns related to the Parcel E landfill will be considered during
the public comment period on the proposed plan for Parcel E, which is expected
to be made available to the public in December 1997.
3.7 COMMENTS FROM ECDC ENVIRONMENTAL
1. Comment:
ECDC Environmental has assumed responsibility for the rail transport and
disposal of tens of thousands of tons of contaminated dredge spoils from a
major Superfund project in the Richmond Harbor. The United Heckathorn
Superfund Project resulted from years of DDT and DDE discharges from a
pesticide manufacturing plant along the Richmond Harbor and docks. The
scope of the project consisted of the dredging, treatment, rail transport and
upland disposal of approximately 100,000 cubic yards of contaminated
marine sediments from two channels in the Richmond Harbor. The bids for
contractors to perform all of that work came in around $8 million. That
cost included everything except EPA's costs of preparing documents and
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providing project management oversight throughout the Superfund
process.
This recent Bay Area example of a remediation project event more complex
than the Hunters Point project is important because it provides a basis for
comparison of how much clean-up work can actually be accomplished at
Hunters Point for a cost substantially less than initial analyses had
portended. This suggests that, not only could the Parcel B contaminated
material be economically and environmentally rail transported off-base, but
that, looking forward to Parcel E, it may be economically feasible to entirely
eliminate the toxic landfill at Hunters Point and make a meaningful
environmental contribution to the long-term future of the Bay Area. This
would truly fulfill the mission of the Navy for "restoration" of the property.
ECDC along with a local Hunters Point minority partner are fully capable
and willing to perform the services required to restore the Hunters Point
property to an environmentally sound condition, and to do so at a cost
considerably lower than that proposed by use of the "Preferred
Alternative," as recommended in the October 15,1996, Draft Final Parcel B
Proposed Plan - Hunters Point Shipyard.
Response: The selected alternative for Parcel B has changed from the preferred alternative
presented in the Parcel B proposed plan. The Navy's selected remedy for Parcel
B will involve excavating and transporting Parcel B contaminated soils to an off-
site facility for treatment (as necessary) and disposal. The ECDC
Environmental disposal facility in East Carbondale, Utah is being considered as
part of the selected remedy. The Navy is currently evaluating options for
transporting Parcel B soils by either rail, truck, or barge.
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